The Manly Warringah NRL club has claimed that rising star Keith Titmuss, who died in November 2020 after collapsing during a pre-season training session, allegedly contributed to his own death. The club's defense, filed in response to a multimillion-dollar legal action by Titmuss's family, asserts that the 20-year-old failed to manage his fitness, weight, and diet during the off-season.
The Titmuss family launched the lawsuit in the NSW Supreme Court, alleging the club was negligent and failed to implement adequate protections against heat illness. However, Manly denies responsibility, stating in court documents that Titmuss's own negligence caused or contributed to his death.
'NRL training is inherently dangerous,' the club's defense reads. 'Any injury, loss and damage suffered by [Titmuss's family]… was caused or contributed to by the deceased's own negligence.'
The club further alleged that Titmuss did not properly investigate any health conditions that could have placed him at greater risk and that he failed to communicate his condition or fitness to coaching staff during the training session. Players were instructed, the club stated, to inform staff if they were feeling ill or not coping with the physical demands.
Manly acknowledged conducting fitness testing on Titmuss four days before his death, which found 'no red flags.' However, the family's statement of claim alleges these tests showed Titmuss's fitness level was the lowest among the training cohort.
Fatal Training Session
The training session on November 23, 2020, began outdoors at 9 a.m. with the temperature at 21.3C and humidity at 92 percent. The outdoor component, involving repeated high-intensity exercises, lasted between 90 and 100 minutes. Following this, players jogged to a dojo for an indoor session that included a passing drill and a cardio circuit. This indoor segment lasted between 15 and 20 minutes.
The family's claim states the dojo was not air-conditioned and that large floor-standing fans were not operational. Manly disputes this, asserting that the dojo's rear doors were open, several fans were available, and enforced drink breaks were provided. The club also noted that 10 staff members were present to monitor the 15 players.
A 2024 coronial inquest found that Titmuss died from exertional heat stroke, likely due to involuntary dehydration. A pre-existing heart condition was found unlikely to have been a contributing factor. The inquest heard a paramedic recorded Titmuss's body temperature at 41.9C, with his heart rate exceeding 140 beats per minute. The coroner concluded that the workout was 'more likely than not inappropriate.'
Legal Claims and Club Response
The Titmuss family alleges that Manly failed to provide a safe system of work, adequately assess Titmuss's fitness, ensure proper hydration, or provide a sufficiently cool training environment. Their statement of claim argues that the club breached its duty of care to Titmuss as an employee.
The family also claims Titmuss struggled physically during an outdoor sprint test three days prior to the fatal session, an allegation denied by Manly. The Sea Eagles had implemented a heat policy after former player Lloyd Perrett reportedly suffered a heat stress-induced seizure during a training session in November 2017. The club is also defending a legal action from Perrett, who alleges exertional heat stroke and other injuries from that session.
A spokesperson for the Manly Warringah Sea Eagles expressed ongoing sadness over Titmuss's death and stated the club could not comment on matters before the court. The spokesperson added that the club welcomed learnings from the coronial inquest and has since worked with the NRL to improve player safety regarding heat illness policies and protocols.
Sources familiar with the proceedings indicated that the family previously received a payment of approximately $1 million from the NRL and Manly's insurer. Titmuss's mother, Lafo, has previously stated the family is seeking justice and accountability, describing her son's death as preventable and asserting that the club failed in its duty of care.