NHL Ducks Concussion Claims by Montador Estate, for Now

The National Hockey League won dismissal, for now, of all claims by the estate of deceased NHL player Steve Montador for brain injuries he sustained during his career, in a ruling by an Illinois federal court.

The estate’s state law negligence claim employing a voluntary undertaking theory is preempted by the Labor Management Relations Act because it is “inextricably intertwined” with the collective bargaining agreements, the U.S. District Court for the Northern District of Illinois said.

The estate alleged that the league undertook various duties to him—including promulgating rules and policies to ensure player safety, and warning players of the ...