The Indiana Supreme Court issued a ruling December 17, 2025, in *Taliyah Brooks v. USA Track & Field, Inc.*, a case stemming from heat-related injuries suffered during the 2020 Olympic Trials that prevented an athlete from making the U.S. Olympic team.
Taliyah Brooks, described in the court's opinion as "a gifted athlete," was competing for a spot on the 2020 United States Olympic Team in Track and Field during the heptathlon event. The Olympic Trials, organized by USA Track & Field and held in Eugene, Oregon in June 2021, took place in intense heat conditions. The trials were delayed a year due to the Covid pandemic, which pushed the competition to 2021 despite being called the "2020" trials.
On the second day of the heptathlon event, Brooks suffered heat-related injuries that prevented her from making the Olympic team. Following her injuries, she filed suit against USA Track & Field, seeking a declaratory judgment to invalidate a release she had signed prior to the competition. Brooks' goal was to clear the way for potential tort claims against the organization if she prevailed on the declaratory judgment issue.
The case proceeded through the Marion Superior Court, where Judge Patrick J. Dietrick presided. The trial court granted summary judgment in favor of USA Track & Field and against Brooks, issuing its orders before Brooks had brought any tort claims against the organization. The timing of subsequent procedural moves became critical to the case's outcome.
Two days after the trial court issued its final judgment, and just days before the statute of limitations for her potential tort claims would expire, Brooks moved to amend her complaint. The trial court denied this motion to amend, setting up the procedural dispute that would ultimately reach the Indiana Supreme Court.
The case was initially appealed to the Indiana Court of Appeals under case number 23A-PL-1685 before being transferred to the Indiana Supreme Court as case number 25S-PL-103. Oral arguments were heard June 26, 2025, with the decision issued nearly six months later.
Justice Massa authored the majority opinion for the court, with Chief Justice Rush and Justices Slaughter and Molter concurring. Justice Goff filed a separate dissenting opinion, indicating the court was not unanimous in its decision.
The court's opinion focuses on "application of the final judgment rule and the order it brings to civil litigation when consistently applied," according to Justice Massa's opening paragraph. The final judgment rule is a fundamental principle in civil procedure that determines when a case is considered concluded for purposes of appeal and other procedural matters.
While the specific holding and reasoning of the court's decision were not detailed in the available excerpts, the case appears to center on procedural questions about when and how parties can amend complaints after final judgments have been entered. The timing of Brooks' motion to amend—coming after the trial court's final judgment but before her tort claims' statute of limitations expired—presented the court with questions about the proper application of procedural rules.
USA Track & Field, headquartered in Indianapolis, serves as the domestic governing body for track and field athletics in the United States. The organization conducts the Olympic Trials every four years to select athletes for the U.S. Olympic team. These trials are highly competitive events where athletes compete under intense pressure for limited spots on the Olympic roster.
The case highlights ongoing concerns about athlete safety during competitions held in extreme weather conditions. Heat-related injuries can be serious and career-threatening for athletes, particularly during multi-day events like the heptathlon that require sustained physical performance.
The procedural nature of the dispute reflects the complex intersection of sports law, personal injury claims, and civil procedure. Athletes who sign releases before competitions often face significant legal hurdles when seeking to pursue injury claims, as these waivers are designed to protect organizing bodies from liability.
The Indiana Supreme Court's ruling in *Brooks* will likely provide guidance for future cases involving similar procedural questions about final judgments and amendment of complaints. The decision may also influence how courts handle cases where athletes seek to challenge releases signed before competitions.
The case represents one of several recent legal disputes involving USA Track & Field and athlete treatment during competitions. As the sport's governing body faces increasing scrutiny over athlete safety and welfare, legal challenges like Brooks' case may become more common.
The dissenting opinion from Justice Goff suggests there was substantial disagreement among the justices about the proper resolution of the procedural issues presented. The split decision indicates the complexity of balancing finality in litigation with parties' rights to seek redress for their claims.
This ruling will be closely watched by sports lawyers and civil procedure specialists as courts continue to grapple with the intersection of athletic competition, injury liability, and procedural fairness in the legal system.