COACHES CATCHING HEAT: CRIMINAL CHARGES FOR THE HEAT-RELATED DEATHS OF HIGH SCHOOL ATHLETES

In the last forty years, sixty-seven high school athletes have died from exertional heat illness.[1] Luckily, heat-related deaths are currently preventable with proper preparation and resources, including an emergency action plan and access to a cold-water immersion tub.[2] However, despite the existence of these life-saving practices and tools, our student-athletes are still at risk of death from exertional heat illness.

High-school sports are wildly under-regulated, and few schools have the necessary systems in place to ensure that their players will survive if they sustain a heat-related injury.[3] The problem, as pointed out by Dr. Douglas Casa, a renowned expert on exertional heat stroke, is that despite all of the life-saving practices available, young athletes “are dying because the people who supervise them are not taking care of them.”[4] In this statement, Dr. Casa appears to be laying the blame on coaches who monitor practices. However, it is still largely unclear if coaches will ever bear legal responsibility for the reasonable prevention of heat-related illness and emergency response when a heat-related injury occurs during a practice that they are overseeing.

Historically, many of the cases involving the heat-related death of a high-school athlete have been resolved with a settlement agreement between the student’s parents and the school board (which generally employs the coaches who oversee practices).[5] The prevalence of these out-of-court settlements means that the courts have rarely had the chance to formally apportion liability among the different actors involved when a child dies due to a heat-related illness. However, a recent case presents the potential for a different means of ensuring accountability and better oversight: bringing criminal charges against the coaches overseeing the student-athlete when they suffered the heat-related injury.

On August 13, 2019, sixteen-year-old Imani Bell (“Imani”) attended her first conditioning practice of the season with the girls’ basketball team at a private school in Clayton County, Georgia.[6] That afternoon, temperatures were in the mid-nineties, and the heat index surpassed one hundred degrees.[7] An hour before their conditioning workout was scheduled to start, Clayton County issued a heat advisory, warning: “No sports or clubs should be outside.”[8] Despite the advisory, head coach Larosa Maria Walker-Asekere (“Asekere”) and Assistant Coach Dwight Broom Palmer led a stadium workout.[9] It was Asekere’s first day on the job, and she claimed to be following the direction of the Elite Scholars Academy athletic director and other personnel.[10] Imani’s parents knew that she would be attending a practice that day but said they had no idea that it would be held outside in the extreme heat.[11]

At the beginning of the workout, coaches instructed players to run up a hill and perform jumping jacks.[12] Imani was noticeably struggling and lagging behind her peers, but her coaches encouraged her and provided her with water.[13] At the end of a short run later in the workout, players were instructed by their coaches to run a set of stairs.[14] At this point, Imani began “pulling herself up by the railing.”[15] Near the top of the stairs, she collapsed and lost consciousness.[16] She was carried indoors, and school officials called 911, but her body temperature was already extremely high.[17] There was no athletic trainer present at the workout, and despite the extreme temperatures, there was no cooling mechanism immediately available.[18] Imani died later that day.[19]

On February 23, 2021, Imani’s parents filed a civil wrongful death suit seeking monetary damages and removal of certain school officials.[20] The lawsuit alleged that multiple named parties failed to follow protocol provided by the Georgia High School Association, including heeding the heat index, monitoring students for signs of overheating, and providing adequate rest periods and water breaks.[21] Additionally, the lawsuit alleged that the school did not have proper equipment on hand, including cold tubs, spray bottles, and iced towels.[22] After a year and a half of court proceedings, the Clayton County School Board settled the case with the Bell family for ten million dollars and pledged to rename the school gym at Elite Scholars Academy in honor of Imani.[23] The school did not acknowledge any fault as part of the settlement.[24]

In addition to the civil suit filed by Imani’s parents, a Clayton County grand jury indicted coaches Larosa Maria Walker-Asekere and Dwight Broom Palmer in July 2021.[25] This was the first time that murder charges have been formally brought against high school coaches accused of negligence.[26] The charges brought against the two coaches include second-degree murder, cruelty to children, and involuntary manslaughter.[27] The grand jury indictment stated that the defendants caused “excessive physical pain by conducting outdoor conditioning training for student-athletes in dangerous heat.”[28] This case is still pending as of March 2025.[29] However, the results of this case are sure to change how both coaches and school boards prepare for potential emergencies involving heat-related illness.

[1] Dan Murphy & Dan Hajducky, Heat Stroke, Air Quality Prompt Concern for Athlete Safety, ESPN (Aug. 3, 2023, 7:00 AM), https://www.espn.com/espn/story/_/id/38122126/extreme-heat-poor-air-quality-raises-concerns-young-athlete-safety

[2] Id.

[3] Id.

[4] See Real Sports 269_ Heat Stroke Video, Zach Martin Memorial Foundation (Feb. 24, 2020, 1:06 PM), https://vimeo.com/393491134.

[5] See, e.g., Adam Regan, Lee County School Board Approves $950K Settlement in Riverdale Player’s Heatstroke Death, News-Press (Dec. 8, 2020, 7:22 PM), https://www.news-press.com/story/sports/high-school/football/2020/12/08/lee-county-school-board-oks-settlement-riverdale-players-heatstroke-death/6497640002/; Robert Jalon, Family of Cristian Navarro Finds Peace, Adamson Ahdoot Injury Attorneys (Mar. 30, 2022), https://aa.law/blog/family-navarro-finds-peace/ (discussing a $9 million settlement reached between the student’s family and the school district).

[6] Eliott McLaughlin & Andi Babineau, Family of Georgia Teen Who Died of Heatstroke After School Basketball Drill Accepts $10 Million Settlement, CNN (Nov. 30, 2022, 10:26 AM), https://www.cnn.com/2022/11/30/us/imani-bell-death-settlement-georgia/index.html

[7] Id.

[8] Mark Strassman, Two High School Coaches Charged with Murder After Basketball Player Died of Heat Stroke Following Practice, CBS News (Aug. 11, 2021), https://www.cbsnews.com/news/imani-bell-coaches-murder-charges-heat-stroke/

[9] Id.

[10] McLaughlin, supra note 6.

[11] Joe Henke, Family of Imani Bell Files Wrongful Death Lawsuit Against School Athletic Director, Coaches, 11 Alive News (Feb. 24, 2021), https://www.11alive.com/article/news/crime/trials/imani-bell-family-files-wrongful-death-suit-against-school-offiicals/85-9826e324-0d4d-4814-8407-99f5b5904d08

[12] Leon Stafford, Imani Bell’s Father Happy with Charges Brought in Daughter’s Death, The Atlanta-Journal Constitution (Aug. 11, 2021), https://www.ajc.com/news/atlanta-news/imani-bells-father-happy-with-murder-manslaughter-charges-in-daughters-death/FMRP54KKIJCEBNHP5XT3CJM3TU/#:~:text=Imani%20tried%20to%20run%20with,assisted %20her%20 up%20the%20stairs.

[13] Id.

[14] Id.

[15] Id.

[16] Johnny Diaz, Family of Georgia Teen Who Died After Basketball Drills Sues School Officials, The New York Times (Feb. 24, 2021), https://www.nytimes.com/2021/02/24/us/imani-bell-lawsuit.html

[17] Id.

[18] Strassman, supra note 8.

[19] Id.

[20] Diaz, supra note 16.

[21] Diaz, supra note 16; Daniel Murphy, Georgia School District Pays $10M Settlement, ESPN (Nov. 29, 2022, 10:35 AM), https://www.espn.com/espn/story/_/id/35138058/georgia-school-district-pays-10m-settlement

[22] Murphy, supra note 21.

[23] Id.

[24] McLaughlin, supra note 6.

[25] Id.

[26] Id.

[27] Strassman, supra note 8; Diaz, supra note 16.

[28] Strassman, supra note 8.

[29] See Clayton County Superior Court - Criminal Case Inquiry, Case No.: 2021CR02142, https://www.claytoncountyga.gov/government/courts/court-case-inquiry/ (last visited Mar. 11, 2025).