A New Jersey federal judge on Monday dismissed a lawsuit brought by former New York Jets safety Rontez Miles, who claims the NFL is liable for an eye injury he suffered after the league told him he couldn’t wear a protective shield. The central problem in Miles’ lawsuit, Judge Julien Xavier Neals found, is that federal labor law preempts his claims as a member of a union. It is the same hurdle that any unionized player often faces when attempting to sue his or her league.
Miles appeared in 54 games for the Jets from 2013 to 2019. He played while suffering alopecia areata, an autoimmune disorder that he said causes him to “experience ocular photosensitivity and photophobia, [which] limits his ability to see well in sunlight or artificial light.” Miles used a protective shield on his helmet until 2017 when an NFL equipment judge informed him equipment rules prohibited use of that shield.
Miles then played in a preseason game against the Detroit Lions without the shield, which diminished protection for his eyes from the stadium lights. As a result, he “did not see an opposing player approach” and failed to take necessary defensive maneuvers. The Lions player then collided with Miles, causing a broken orbital bone of the right eye and other serious injuries. Miles required surgery, which caused him to miss several games.
Though his NFL career continued, he says he still suffers “severe pain.”
Two years ago, Miles sued the NFL for negligence and violations of the New Jersey’s law against discrimination and the Americans with Disabilities Act. He argued, among other points, the league should have permitted a reasonable accommodation for his disability and that it breached a duty of care to him.
Like all NFL players, Miles’ employment relationship was governed by the CBA and the standard NFL player contract, both of which are bargained by the league and NFLPA. Those documents authorize restrictions on equipment and generally dictate that injury disputes go to arbitration. The NFL insisted his claims could not be resolved without interpreting the CBA and relevant rules, including an assessment if the league possessed a legitimate, non-discriminatory reason for barring the shield.
Judge Neals agreed, noting that federal labor law preempts state-law claims that “depend upon the meaning of a collective-bargaining agreement.”
He observed that to evaluate Miles’ legal arguments, a court would “have to interpret the CBA to determine whether the NFL had any obligations under the CBA or incorporated documents to make certain accommodations.” That type of evaluation triggers preemption since it requires CBA analysis.
Similarly, Neals stressed that a court could not evaluate whether the league was negligent with respect to Miles unless it interpreted the CBA to determine the “nature and scope” of any duty of care and whether the league violated that duty. The fact that Miles was permitted to play with the shield for several seasons would be relevant in a negligence analysis, but that analysis can’t occur in court due to labor law preemption.
The judge also found Miles’ ADA claim lacking, because Miles failed to follow necessary procedure. Miles didn’t file a charge of discrimination with the EEOC, a required step. It meant, Neals wrote, that Miles failed “to exhaust his administrative remedies” before turning to the courts, and therefore the claim must be dismissed.
Miles can appeal the ruling to the U.S. Court of Appeals for the Third Circuit.
Miles also has a pending criminal law matter. In September he was charged with aggravated assault, burglary and other offenses in Pennsylvania after he was accused of breaking into a home and attacking its occupants.