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Physician can’t claim comp immunity in baseball player death suit: Fla. court - Business Insurance Skip to content Register for free Search Search Log In Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Physician can’t claim comp immunity in baseball player death suit: Fla. court by Louise Esola Claims Disputes , Workers Comp Coverage , Workplace Safety May 15, 2026 A Florida appeals court ruled Friday that a physician sued over the death of a Minnesota Twins baseball prospect cannot rely on Minnesota workers compensation immunity to avoid a wrongful death lawsuit. The Florida 6th District Court of Appeal in David Olson, M.D. v. Christopher and Tammy Costello, as Personal Representatives of the Estate of Ryan Costello, et al. affirmed a Lee County Circuit Court ruling that Florida law applies to Dr. David Olson’s immunity defense. Ryan Costello, a Twins prospect, died in 2019. According to media reports, he was found dead in his hotel room in Auckland, New Zealand, where he had traveled to play for the Auckland Tuatara of the Australian Baseball League; team officials said at the time that he died in his sleep, apparently of natural causes. His estate sued Dr. Olson and others in Florida state court, alleging medical negligence in connection with care provided in Florida before his death. Prior reports on the lawsuit said Mr. Costello underwent a spring training physical in Florida and that his family alleged an abnormal electrocardiogram was not properly addressed. Dr. Olson moved for summary judgment, arguing Minnesota law applied and that, under Minnesota workers compensation law, he was immune from the estate’s claims. The trial court denied that motion, finding factual disputes remained over whether Minnesota law applied, according to the ruling. The trial court later separately granted summary judgment on the choice-of-law issue, finding Florida law governed Dr. Olson’s workers compensation immunity defense. Under Florida’s Workers’ Compensation Act, professional athletes are excluded from the definition of employment, the appeals court said. The appeals court dismissed Dr. Olson’s challenge to the first order, saying it lacked jurisdiction because the order denying summary judgment did not expressly state that he was not entitled to workers compensation immunity as a matter of law. But the court said it had jurisdiction to review the second order because its legal effect was to eliminate Dr. Olson’s ability to assert Minnesota workers compensation immunity at trial. Applying Florida’s “significant relationships” test for conflicts of law, the appeals court said the trial court used the correct standard and reached the correct result. The court affirmed the ruling that Florida law applies and that Florida workers compensation law does not bar the estate’s claims. 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