Supreme Court of Maryland Holds that Negligence by Statute Violation Requires Proof of Proximate Cause

 Homer Walton, et al., v. Premier Soccer Club, Inc., et al., No. 11, 2025 Md. LEXIS 143 (April 24, 2025). Opinion by Gould, J.

Fourteen-year-old youth athlete, Sydney Walton, while participating in a recreational soccer league, collided with another player during a routine practice drill causing Sydney to fall into a wooden perimeter wall, ultimately resulting in a concussion. As a result, Sydney and her parents (the “Waltons”) collectively brought a negligence claim against Premier Soccer Club, Inc., alleging that coach Lucio Gonzaga’s negligence contributed to this concussion through his failure to adhere to section 14-501 of the Health-General Article of the Maryland Annotated Code (HG § 14-501). Both the Baltimore County Circuit Court and the Appellate Court rejected the Waltons’ claim and granted the Defendants’ motion for summary judgment. The Waltons petitioned the Supreme Court of Maryland to hear the case.

In order to prove negligence in Maryland, the plaintiff must show: (1) the defendant owed a duty of care to the plaintiff; (2) the defendant breached that duty; and (3) there was a legally cognizable causal relationship between the breach of duty and the harm suffered by the plaintiff; otherwise known as the “proximate cause” of the injury. Proximate cause is further broken down into two sub-elements: (1) causation-in-fact – whether the defendant’s conduct actually produced the injury – and (2) legal causation – whether the plaintiff’s injury was a foreseeable result of the defendant’s conduct.

Moreover, where a prima facie case of negligence is premised upon a showing that the defendant violated a statute, it is presupposed that the defendant did, in fact, owe a duty to the plaintiff and subsequently breached that duty by failing to adhere to the statutory mandate; however, this doctrine is not dispositive and proximate cause must still be shown. This legal doctrine is known as the Statute or Ordinance Rule (the “Rule”).

Here, the Waltons relied on the Rule in making their claim against Premier and Coach Gonzaga for failure to abide by HG § 14-501, which sets forth guidelines that youth sports programs must follow in order to have access to local government facilities for their games and practices. In particular, HG § 14-501(b)(1) requires that youth sports programs provide information regarding concussions and head injuries to coaching staff, players, and their parents as a means of raising awareness of these inherent risks and how to structure practices with the ultimate goal of lowering the risk of head injuries.

Despite Premier and Gonzaga’s neglect in distributing the concussion policy material in violation of the statute, the Waltons were unable to show 1) that this was the cause-in-fact of Sydney’s concussion and 2) that Sydney’s concussion was a foreseeable result of not providing the Waltons with the concussion policies. This discrepancy was further exacerbated by the fact that Plaintiffs’ counsel neglected to include relevant copies of the concussion policies in their summary judgment opposition; thereby preventing the Supreme Court of Maryland from taking notice of the relevant policies in the statute, as the Court may only review the grounds upon which the trial court relied in granting summary judgment. 

Plaintiffs’ counsel attempted to argue, alternatively, that the Rule does not require a showing of cause-in-fact, but merely that the plaintiff was in the class of people that the statute was intended to protect and that the harm suffered was of the type that the statute’s drafter meant to prevent; however, the Court emphasized that accepting this interpretation of the Rule would be antithetical to the precedent set forth in prior cases.

Ultimately, the Court held that the Rule specifically requires that plaintiffs show cause-in-fact in a negligence claim, as to rule otherwise would allow many negligence cases involving statutory violations to unduly prejudice the defendant and create a windfall ruling in favor of the plaintiff. Furthermore, the Maryland General Assembly did not intend for the concussion policies to completely remove the risk of concussion in youth sports. Concussions are an inherent risk when engaging in athletic events; thereby negating the Waltons’ claim that, should the Court consider the concussion policies, cause-in-fact would be proven. Finally, because the Court is restricted to solely review the facts of the prior cases regarding the summary judgment record and Plaintiffs’ counsel merely alluded to the text of the concussion policies, the Waltons failed to include evidence which could lead a jury to find a genuine dispute of material fact in the case and summary judgment was proper. 

- Vincent Bedessem, Law Clerk