A recent appellate court decision has upheld the dismissal of a negligence lawsuit brought by a former stadium worker against a security company, following an incident in which the worker was assaulted during a football game. The ruling clarifies the legal responsibilities of private security firms operating under contract at public venues and addresses the standards for proving negligence in such cases.
The complaint was filed by Joshua Bradley, Sr., who represented himself in the proceedings. It was submitted to the Cuyahoga County Court of Common Pleas on October 23, 2024, naming Apex Security Group, Inc. as one of several defendants. The case arose from an altercation that took place at Cleveland Browns Stadium during an October 31, 2022 football game between the Cleveland Browns and Cincinnati Bengals.
According to court documents, Bradley was employed by Minutemen and assigned to work at the stadium on the night of the incident. While taking out trash during the event, he became involved in an exchange with several male fans. During his deposition, Bradley stated that he did not initially feel threatened because “they were ‘just cracking jokes.'” He also acknowledged that four security guards walked past but did not alert them or anyone else since he did not perceive any danger at that time. The situation escalated when one individual, identified as Tarelle Wilson, punched Bradley in the face. Wilson was later charged with felonious assault and ultimately pled guilty to attempted felonious assault.
Bradley’s original lawsuit alleged negligence against multiple parties including Cleveland Browns Football Company and other entities associated with stadium operations. He later amended his complaint to add Aramark Sports and Entertainment Services, LLC and sought punitive damages against all defendants. Over time, all parties except Apex Security Group were dismissed from the suit.
Apex moved for summary judgment on May 1, 2025. The trial court granted this motion in favor of Apex Security Group. In his appeal, Bradley raised several assignments of error: misapplication of Ohio personal injury and negligence law; improper exclusion or disregard of key evidence; allegations of judicial misconduct; abuse of discretion regarding motions for default judgment; and procedural errors affecting fairness.
The appellate opinion addressed each claim in detail. On the primary issue of negligence, the court noted that “there generally is no duty to prevent a third person from causing harm to another absent a special relation between the parties.” It cited established Ohio law stating that business owners must warn or protect invitees only when they know or should know there is substantial risk posed by third parties on their premises.
The opinion further explained that Apex did not own or control Browns Stadium but operated under contract with Cleveland Browns Stadium Company LLC to provide security services. Whether such companies owe duties depends on their contractual obligations with property owners: “There is no basis…for imposing a higher duty on…a privately retained security guard to protect members of the general public from offenses of third persons.” In this case, neither specific duties nor job site rules were included in evidence.
During his deposition testimony, Bradley admitted it was not probable someone would punch him while performing his job duties: “It’s not highly probable, but it’s not impossible.” He also stated he only felt physically threatened immediately before being struck. Based on these facts and relevant legal standards for foreseeability and duty under Ohio law, both trial and appellate courts concluded there was no triable issue showing Apex acted negligently.
Bradley also argued that critical evidence—such as affidavits, photographs, videos—was excluded without hearings or findings by the trial court. However, according to Civ.R. 52 cited by the appellate panel: “Findings of fact and conclusions of law are not necessary when a trial court rules on a party’s motion for summary judgment.” Furthermore, courts are not required to hold hearings prior to granting summary judgment unless specifically requested—and even then have discretion whether or not to do so.
Regarding claims of judicial bias or misconduct by the trial judge toward him as a pro se litigant, the appellate panel found no evidence supporting such allegations: “We see nothing to suggest that the trial court harbored a hostile feeling…the record instead suggests that the trial court acted with restraint.”
Other arguments concerning denial of default judgments were dismissed because they pertained only to previously dismissed defendants rather than Apex Security Group itself.
In conclusion, all five assignments of error raised by Bradley were overruled and summary judgment for Apex Security Group affirmed. The appellate decision orders costs taxed against appellant Joshua Bradley Sr., with instructions sent back for execution consistent with this ruling.
Attorneys listed include James T. Tyminski Jr., Kathleen M. Kennedy (for appellee Apex Security Group), while Joshua Bradley Sr. appeared pro se. Judges explicitly named are Michael John Ryan (presiding), Anita Laster Mays, and Eileen A. Gallagher (concurring). Case ID is No. 115092.
Source: 2026Ohio1188_Bradley_Sr_v_Cleveland_Browns_Football_Company_LLC_Opinion_Ohio_Court_of_Appeals.pdf
