Youth sports coaches should take note of a recent Connecticut Superior Court case in which the court considered whether a coach’s motivation tactics, which included berating his players, amounted to an actionable tort.

In Civitella v. Pop Warner Football, the father of a Pop Warner football player sued the league and the head coach of his son’s team, alleging slander and intentional infliction of emotional distress, after the coach called his son various names and insulted him in front of his teammates. The defendant coach claimed that he was attempting to motivate the young player.

The defendants filed a Motion to Strike, challenging the legal sufficiency of the claims in the Complaint, which successfully eliminated the plaintiff’s slander claim. However, the Court (Radcliffe, J.), allowed the plaintiff’s claims of intentional infliction of emotional distress to be considered on their merits. In her ruling, Judge Radcliffe deemed the coach’s behavior to be unacceptable:

“Although generations of high school and college football players can probably recall coaches who employed insensitive, insulting and what would now be politically incorrect language in an effort to motivate and inspire players, that approach is now as obsolete as the single wing offense.”

“Where once coaches may have enjoyed free rein, and used that latitude to employ equal opportunity insults, in this era of political correctness, speech codes on college campuses, and heightened sensitivity, comments which would have produced a shrug of the shoulders decades ago, may now be considered ‘outrageous’ and unacceptable, without regard to motive or intent.”

Following Judge Radcliffe’s ruling, the defendants filed a Motion for Summary Judgment, under which the defendant must demonstrate that there is no genuine issue of material fact to be decided by the court. The Motion was heard by Judge Matasavage, who found that the plaintiff failed to demonstrate that his son had suffered any emotional distress as he had not sought medical treatment for anger or depression and his friends, grades, activities and hobbies did not change. Judge Matasavage also addressed the coach’s behavior:

“Everyone, at one time or another, will experience the less pleasant side of a teacher, coach, official, supervisor, boss, colleague, or even a friend. Those cases of embarrassment, humiliation, hurt feelings and other less debilitating, more transient forms of suffering … are not sufficient to impose liability.”

In a good-natured footnote, Judge Matasavage also took issue with Judge Radcliffe’s assertion that the defendant coach’s approach was as “obsolete as the single wing offense,” noting that the popular wildcat offense is a direct offshoot from the single wing.

The defendant ultimately prevailed in this case because the plaintiff was unable to prove damages. However, the takeaway for youth coaches is that the courts may view certain coaching tactics, such as berating players, as obsolete, especially when young players are involved. For more information, please contact Daniel B. Fitzgerald (dfitzgerald@ brodywilk.com).