(Image Credit: IMAGN) The Kentucky Sentate gavel rests on the wooden sound block in the Kentucky Senate chambers before the first day of Concurrence began at the state Capitol in Frankfort, Ky. March 13, 2025.
Del Mar, California – The California Supreme Court has declined to review a civil jury verdict awarding more than $46 million to Jack Greener, a Brazilian jiu-jitsu student who was rendered quadriplegic during a 2018 sparring session at a San Diego County martial arts gym. With post-judgment interest, the total award now exceeds $56 million, court records show—solidifying one of the largest personal injury judgments of its kind in the state’s history.
Greener, then 23, sustained a catastrophic spinal cord injury on November 29, 2018, during a session at Del Mar Jiu-Jitsu Club. His opponent was not a fellow student, but his instructor, Francisco Iturralde—a second-degree black belt and employee of M. Phelps, Inc., the company that operates the gym. According to the San Diego County Superior Court’s findings, Iturralde executed a maneuver during live sparring that placed the full weight of his body on Greener’s neck, fracturing cervical vertebrae and permanently damaging his spinal cord.
The jury’s decision rested on a specific legal distinction: while sports like Brazilian jiu-jitsu involve inherent physical risk, instructors can be held liable when their conduct increases that risk unreasonably. In this case, jurors concluded that Iturralde’s actions did exactly that. Citing California Civil Jury Instruction No. 471, which governs sports instructor liability, the court determined that Iturralde breached the standard of care by amplifying the danger in a way not intrinsic to the sport.
Following a four-week trial, the jury awarded Greener $46,475,112.33 on March 28, 2023, to cover extensive medical costs, pain and suffering, and future lost wages. The defendants appealed, challenging both the jury instructions and the trial judge’s decision to exclude certain evidence. But on December 31, 2024, the California Court of Appeal, Fourth Appellate District, upheld the trial court’s rulings in full, concluding that the jury had been correctly guided and that no reversible errors had occurred.
When the defendants petitioned the California Supreme Court to review the appellate ruling or to depublish the opinion, both requests were denied, cementing the trial court’s findings as precedent.
The case—Greener v. M. Phelps, Inc.—now serves as a defining moment in California’s sports liability law, reinforcing that while athletic pursuits carry risk, those who teach them must not turn that risk into reckless harm.
