Sudden Death: Examining the Duty of Care in Football Training Camp Fatalities

76 Pages Posted: 29 May 2011

Date Written: January 7, 2002


According to figures from a study performed by the University of North Carolina National Center for Catastrophic Sports Injury Research, 18 high school and college players died of heat stroke or related conditions since 1995. Northwestern senior safety, Rashidi Wheeler, succumbed to bronchial asthma-related complications during a “voluntary” August 3, 2001 pre-season practice, while his teammates continued to run appropriately named “suicide” windsprint drills as he collapsed. Wheeler had suffered at least 30 asthma attacks during his career with Northwestern and was inexplicably encouraged by trainers to breath into a bag after his last episode, presumably hastening his demise.

Unlike scholastic football, there had only been two deaths on the field in the NFL until recently. J.V. Cain, a tight end for the St. Louis Cardinals died of a heart attack in a 1979 practice, and Chuck Hughes, a wide receiver for the Detroit Lions, also from heart heart failure, in 1972 during a game against the Chicago Bears.

The National Center for Catastrophic Sport Injury Research, based at the University of North Carolina at Chapel Hill, reports that 14 high school football players, two college football players, and one semi-pro player died from heatstroke from 1995 to 2000. On August 1, 2001, Minnesota Vikings All-Pro offensive tackle, Korey Stringer, suffered the first heat-related death in the NFL’s 82 year history. Stringer had weakened noticeably from the rigor of preseason conditioning in the previous practice, and with an ambient “heat index” of 103 degrees at the Mankato Minnesota training facility, his body temperature eclipsed 108.8 degrees and he ultimately experienced massive heat stroke induced multiple organ system failure.

Both Stringer and Wheeler are suspected of using performance enhancers containing “ephedra,” a generally unregulated herbal supplement that has been attributed to at least 17 deaths and 800 illnesses. Wheeler’s autopsy indicated trace amounts of the controversial substance and while Stringer’s did not, the Vikings have stated that players saw him ingest performance enhancers prior to that fateful session and that numerous supplements were located in his locker. Not suprisingly, the NFL banned ephedrine in the aftermath of Stringer’s demise as had the NCAA and IOC prior to these tragedies.

Keywords: training camp deaths, football, NCAA, NFL, duty of care, ephedra, heat stroke, northwestern wildcats, minnesota vikings, workers compensation, death benefit limits, kleinknecht, OSHA

Suggested Citation

Pekarek, Edward, Sudden Death: Examining the Duty of Care in Football Training Camp Fatalities (January 7, 2002). Available at SSRN: or

Edward Pekarek (Contact Author)

Pace Law School ( email )

80 North Broadway
White Plains, NY 10603
United States


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