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The Indiana Supreme Court has blocked the revival of a lawsuit brought by an Olympic athlete against USA Track & Field after she collapsed from heat-related injuries at the 2021 U.S. Olympic trials.
In a 4–1 decision issued Wednesday, the justices held that Marion Superior Court Judge Patrick Dietrick properly denied heptathlete Taliyah Brooks’ attempt to amend her complaint after the court already had ruled in favor of Indianapolis-based USA Track & Field.
However, the state’s high court emphasized that its decision turned on procedure rather than the merits of Brooks’ underlying claims. She had argued that a liability waiver she signed with USA Track & Field should not apply because the governing body was negligent when it failed to delay the Olympic qualifying trials to avoid the excessive heat.
“We recognize the gravity of Brooks’ allegations against USATF and the impact her heat exhaustion at the Olympic Trials had on her Olympic dreams, which were so close to being realized,” Justice Mark Massa wrote in the majority opinion. “Rather, our decision applies and clarifies the procedure for bringing these claims.”
Ultimately, the high court’s ruling clarified that Indiana Trial Rule 15(A), which generally allows liberal amendment of pleadings during the course of a lawsuit, does not apply once a final judgment has been entered.
Brooks collapsed from heat-related injuries during the second day of the U.S. Olympic Trials in Eugene, Oregon, in June 2021. Track surface temperatures exceeded 140 degrees. She was unable to finish the event and did not make the Olympic team in 2021. (Three years later, she did win the chance to compete in the 2024 Olympics and finished 11th in the heptathlon.)
In November 2022, Brooks sued USA Track & Field in Marion Superior Court, seeking a declaratory judgment that a waiver and indemnity agreement she signed before the trials was unenforceable.
She said she needed that ruling before pursuing tort claims against the national track and field governing body because the agreement required athletes to indemnify the organization for litigation costs.
The trial court granted summary judgment in favor of USA Track & Field on June 21, 2023, finding the waiver enforceable.
Two days later, Brooks moved to amend her complaint to add negligence and related claims, days before the statute of limitations expired. The trial court denied the motion, concluding that final judgment had already been entered.
The Indiana Court of Appeals later agreed the waiver was enforceable but ruled the trial court should have allowed the amendment. The Supreme Court affirmed the trial court’s ruling.
The state’s high court ruled that once final judgment is entered, there is no complaint left to amend. The ruling emphasized that the final judgment rule promotes certainty and efficiency in litigation and cannot be altered by a party’s strategic choices.
The court said Brooks could have amended her complaint earlier or filed a separate lawsuit before the statute of limitations expired.
Justice Geoffrey Slaughter and Justice Derek Molter joined the opinion, along with Chief Justice Loretta Rush.
Justice Christopher Goff dissented, arguing that the waiver agreement was unenforceable as a matter of public policy and that summary judgment should not have been entered in the first place.
William Bock, Brooks’ attorney at Kroger Gardis & Regas, said he agreed with Goff’s position. And despite the court’s majority ruling, Bock said he appreciated that the justices gave the case a full airing.
He said the only legal option left in the case would be to ask the court for reconsideration, but he said he doesn’t know if that’s a path that Brooks wants to pursue or if it makes sense.
“I think she’s happy that we gave it a 100% effort,” Bock said. “Her goal was always primarily just to stand up for the rights of athletes.”
Crystal Rowe, USA Track & Field’s attorney at Kightlinger & Gray LLP, did not not immediately respond to a request for comment.
The case is Taliyah Brooks v. USA Track & Field, Inc., 25S-PL-103
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