SIGNIFICANT CASE SUMMARIES

Maryland Case Summary

Walton v. Premier Soccer Club, Inc.
Maryland Supreme Court
No. 11, Sept. Term 2024

Decided: April 24, 2025

While violation of a statute designed to protect a particular plaintiff is evidence of negligence, to survive summary judgment, plaintiffs must provide evidence to establish proximate cause.

Background

Plaintiffs, on behalf of their daughter, sued after their daughter sustained a concussion while playing soccer at Defendants’ field. Plaintiffs alleged that Defendants were liable because they violated a statute requiring youth programs to make information on concussion and their risks available to coaches, youth athletes and parents. Plaintiffs claimed they were never provided with the literature required under the code, and that this amounted to negligence per se. The Circuit Court granted Defendants’ Motion for summary judgment on Plaintiff’s negligence per se theory. Plaintiff appealed.

The Appellate Court of Maryland affirmed. It held that when relying upon a statute to establish a violation of negligence, a plaintiff must satisfy a two-prong test to make out a prima facie case of negligence. First, plaintiff must prove that the plaintiff’s injury was what the statute intended to prevent, and that the plaintiff was a member of the class that the statute intended to protect. Second, a plaintiff must prove that the violation of the statute was the proximate cause of the plaintiff’s injury. While the Appellate Court held that Plaintiffs satisfied step one of the test, it disagreed on step two.

Holding

The Supreme Court of Maryland held that the violation of a statute designed to protect a particular plaintiff is evidence of negligence. To survive summary judgment, however, a plaintiff must provide sufficient evidence to establish the two components of proximate cause: (1) causation-in-fact; and (2) legal causation. If the plaintiff can prove that the defendant’s breach did, in fact, cause the plaintiff’s injury, the next step is to determine if defendant’s breach constitutes a legally cognizable cause of the plaintiff’s injury (i.e., whether the injuries were a foreseeable result of defendant’s negligent acts).
Here, the Plaintiffs presented no evidence that the alleged violations of the statute at issue were either the but-for cause of their daughter’s injuries or a substantial factor in causing them. Thus, Plaintiffs did not raise a genuine dispute of material fact on the issue of proximate cause. The Supreme Court affirmed the Lower Courts’ holdings.

Questions about this case can be directed to Alex Mitchell at (443) 641-0563 or amitchell@tthlaw.com.