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NFL Turf Injuries Renew Debate Over League Liability

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For a sport as contact driven as professional football, it is not a question of if players will get injured, but when. Over the years, prominent National Football League (“NFL”) players suffering career-altering injuries have raised questions about the NFL’s legal duty that may arise in these scenarios. Increased scrutiny centered on the NFL’s liability for player safety is pushing the league to take further action to mitigate preventable risks, specifically when it comes to artificial turf fields.

 

The NFL’s Demonstrated Liability

 

While assumption of risk is a recognized formality within the NFL, ongoing concussion litigation against the League has demonstrated that liability can arise when the NFL fails to adopt adequate safety measures.[2] In 2013, the NFL chose to settle for $765 million with former players who suffered concussion-related injuries.[3] While the NFL has avoided admitting its liability for those injuries, they have acknowledged the link between football-related head injuries and serious diseases like Chronic Traumatic Encephalopathy (“CTE”).[4] The NFL began taking precautions to prevent concussion injuries in 2011, and again in 2022 by amending its concussion protocol in response to the pressure that litigation and the National Football League Players Association (“NFLPA”) has put on the League.[5] This raises the question: If the NFL is obligated to implement preventive concussion protocols,[6] should the NFL also be required to address turf-related injuries?

 

 

Notable Injuries

 

In the beginning of the season, Najee Harris of the Los Angeles Chargers tore his ACL in the second quarter against the Denver Broncos during their week three matchup.[7] Notably, Harris played the majority of his career on grass fields prior to this game.[8] His injury, however, which was not a result of physical contact, had occurred on an artificial turf field and was severe enough to end his 2025 season.[9] Harris’s injury is just one example of an increasingly dangerous trend in the NFL, bringing the debate on artificial turf fields to the forefront of many players’ minds.[10]

 

Joe Burrow of the Cincinnati Bengals was removed from the field during a game earlier this year after suffering turf toe against the Jacksonville Jaguars in week two of the 2025 season.[11] His injury requires surgery, with Burrow expected to be on the IR for the next three months.[12] Notably, Burrow’s injury occurred at Paycor Stadium, which utilizes artificial turf.

 

What Makes Turf More Dangerous?

 

Studies presented by the NFLPA, and published in the American Journal of Sports Medicine, have shown that artificial turf does not release cleats as easily as natural grass, resulting in a 16% increase in lower body injuries and a 20% increase in non-contact injuries.[13] Injuries like Harris’s ACL tear and Burrow’s Turf toe have become more prevalent since artificial turf can magnify the stress on players’ joints compared to natural grass.[14]

While it is naive to claim that every injury sustained on a turf field would have been prevented if it occurred on grass, this trend has prompted a growing number of players and the NFLPA to advocate for a league-wide return to natural grass.[15]

 

The NFL’s CBA and the NFLPA Union

 

Under the NFLPA’s current Collective Bargaining Agreement (“CBA”), the NFL is contractually responsible for ensuring every NFL-sanctioned field complies with the Field Surface Safety & Performance Committee’s Mandatory Practices for Maintenance of Natural and Synthetic Surfaces for NFL Games.[16] The NFL is also responsible for improving the safety of NFL players and field surfaces.[17] Such provisions place a burden of safety and responsibility on the League, with mechanisms in place to hold them accountable for failing to abide by these restrictions, regulate official NFL fields, or disregarding players’ safety.

 

The NFL continues to contest negative findings about artificial turf fields.[18] Yet, regardless of the League's stance, a growing amount of scientific evidence proves the possibility of exacerbated injuries caused by artificial turf fields.[19] The NFL can no longer ignore these concerns. Player testimony and evidence presented by the NFLPA have highlighted a clear connection, prompting a conversation with the NFL regarding options to mitigate the risk that artificial turf poses. [20]

 

The Future of Turf Fields

 

Moving forward, as data continues to support the dangers of artificial turf fields, pressure on the NFL to make changes may extend beyond reputation and social pressure. The NFL may face liability under contractual requirements set forth in the CBA and the precedent of the concussion litigation if it fails to address the heightened risks artificial turf poses to players.

 

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Julia Bisson (staff writer) is a 1L at Villanova Law from Portland, Maine. She graduated from Bates College with a double major in English and Political Science. At Villanova, she is an Access to Justice Fellow, a member of the Pro Bono Society, First Generation Lawyer society, and plays on an intramural soccer team. Julia enjoys running, hiking, and playing guitar in her free time. 




Referecnes

[1] See Carol M. Highsmith. (March 21, 2024). Upsplash.

[2] See Kelton McLeod, Assumption of Risk in the NFL, Washington Journal of Law, Technology & Arts (Jan. 20, 2023). https://wjlta.com/2023/01/20/tough-to-watch-assumption-of-risk-in-the-nfl/

[3] See Andrew Lawrence, Brain Injuries and legal battles: the NFL’s persistent problem with CTE, The Guardian (Jul. 29, 2025). https://www.theguardian.com/us-news/2025/jul/29/nfl-cte-brain-disease

[4] Id.

[5] See JC Tretter, Concussion Protocols: Where We Stand Now, NFLPA, (Oct. 26, 2022).  https://nflpa.com/posts/concussion-protocols-where-we-stand-now

[6] See NFL Football Operations, Innovations in Player Safety Help Drive NFL Preseason Concussions to Record Low, NFL Football Operations Updates (Oct. 4, 2024). https://operations.nfl.com/updates/the-players/innovations-in-player-safety-help-drive-nfl-preseason-concussions-to-record-low/

[7] See Nick Shook. Najee Harris suffers torn Achilles: How does injury impact Chargers offense? (Sept. 22, 2025). https://www.nfl.com/news/najee-harris-torn-achilles-how-does-injury-impact-chargers

[8] See Chris Roling, Former Chargers player opens up about the cause of Najee Harris' injury, Sports Illustrated (Sep. 23, 2025). https://www.si.com/nfl/chargers/chargers-player-opens-up-cause-najee-harris-injury

[9] Id.

[10] See Ayomide Adeduyite, Calls Mount for NFL to Take Action After Devastating Najee Harris News, AthlonSports (Sept. 24, 2025). https://athlonsports.com/nfl/los-angeles-chargers/nfl-rule-debate-after-najee-harris-news

[11] See Saad Yousuf, What is turf toe? Explaining the injury sidelining NFL QBs Joe Burrow, Brock Purdy, New York Times (Sept. 15, 2025). https://www.nytimes.com/athletic/6629484/2025/09/15/turf-toe-nfl-joe-burrow-brock-purdy/

[12] Id.

[13] See Christina D. Mack et al., Higher Rates of Lower Extremity Injury on Synthetic Turf Compared With Natural Turf Among National Football League Athletes: Epidemiologic Confirmation of a Biomechanical Hypothesis, Sagepub (Nov. 19, 2028). https://journals.sagepub.com/doi/10.1177/0363546518808499?url_ver=Z39.88-2003&rfr_id=ori:rid:crossref.org&rfr_dat=cr_pub%20%200pubmed

[14] Id.

[16] See 2020 NFL Collective Bargaining Agreement, Article 39, Section 11(c).

[17] Id. Article 39, Section 11

[18] See Patrick Hollerton, Grass is greener? NFL’s field surface dilemma still a concern as 2024 season kicks off, Cronkite News (Sept. 5, 2024) https://cronkitenews.azpbs.org/2024/09/05/nfl-field-surface-dilemma-concern-2024-season/

[19] Mack, supra.

[20] See JC Tretter, Why the NFL's Approach to Field Surfaces Is Uneven, NFLPA (Apr. 19, 2023). (https://nflpa.com/posts/nfl-approach-field-surface-uneven)

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