Los Angeles Angels starting pitcher Tyler Skaggs died on July 1, 2019, in a room at the Southlake, Texas, Hilton. Investigations have now been initiated by local authorities, Skaggs’ family, and the MLB. His death, caused by the cocktail of powerful drugs found in his system by an autopsy, has raised a host of thorny legal questions and a high probability of a wrongful death lawsuit aimed at the team.
Skaggs, 27, was in Southlake with the Angels for a series of games against the Texas Rangers and Houston Astros, having arrived with the team on June 30. On the afternoon of July 1, a teammate texted and called Skaggs repeatedly about joining him for lunch, but the teammate grew concerned when he received no response. Skaggs was found dead in his hotel room that afternoon, having choked on his vomit. There was no evidence of a struggle or any physical trauma to Skaggs.
The Tarrant County medical examiner’s office released its toxicology report on August 30. According to their investigation, Skaggs had taken a combination of Fentanyl and oxycodone, along with enough alcohol to put him at about 150% of the legal limit for intoxication. The toxicology report showed that Skaggs had about 3.8 nanograms per milliliter of Fentanyl in his system, an amount that can occasionally be but isn’t necessarily fatal. Fentanyl, a synthetic opioid, is a powerful central nervous system depressant, cited by a 2018 federal report as the drug most commonly involved in overdoses.
The release of the toxicology report prompted Skaggs’ family to release a statement that shared their heartbreak at learning that his death had stemmed from substance use. “That is completely out of character for someone who worked so hard to become a Major League Baseball player and had a very promising future in the game he loved so much.” The statement also expressed appreciation for the work of the Southlake Police Department for its work on the investigation. The statement noted that the family was “shocked to learn that may involve an employee of the Los Angeles Angels,” and that they had retained a local Texas attorney to learn the truth about Skaggs’ death. In response, a spokesman for MLB said he was “unaware of this allegation” and stated that MLB would be conducting its own investigation into the death.
Skaggs, a popular and reliable member of the Angels, was survived by his parents as well as the wife he had married only in December. The death of a man with such promising earning potential inevitably raises questions about whether a third party may be held liable through a wrongful death suit. The Skaggs family statement implied that they’re already mulling a claim against the Angels, though the circumstances of an Angels’ employee’s involvement wasn’t made clear. Randy Hardin, the Skaggs’ family attorney working out of Texas, told reporters that he and his clients were “going to want to know how it came about that those drugs were ingested and whether or not others are responsible for what happened.”
Major League Baseball prohibits both oxycodone and Fentanyl for use by players, but neither are drugs for which MLB tests its players in the absence of probable cause or participation in a drug treatment program. It is possible that the league has records indicating that Skaggs had tested positive for these substances in the past, or that he had received an exemption to use the drugs for a condition, but these records are not public. Skaggs’ family may, however, decide to waive the confidentiality of these records so that they can discover their contents.
If an Angels employee provided these drugs to Skaggs, the team might be left paying the costly bill for his wrongful death—a claim estimated to be valued in the realm of nine figures. Skaggs, who had avoided serious arm injury since 2016, was approaching eligibility for free agency when he died. He had a better-than-league-average ERA+ stat and was poised to set a career high for innings pitched for the second year in a row. While these factors could lead to a significant wrongful death award, if a further investigation revealed that Skaggs’ struggle with drugs and alcohol was longer-lasting than anyone had realized, this could severely hamper the chances of succeeding in a claim against the Angels. It would likely mean that the family would need to learn whether another party might bear responsibility for Skaggs’ fentanyl use.
