Revised Code of Washington
Wash. Rev. Code § 28A.600.190 (2026)
Youth sports—Concussion and head injury guidelines—Injured athlete restrictions—Short title
✓ current as of May 2026
Find cases:
SyfertCases citing this section
WA-LEGapp.leg.wa.gov
JustiaTitle on Justia
CornellLII Search
CasesGoogle Scholar
(1)(a) Concussions are one of the most commonly reported injuries in children and adolescents who participate in sports and recreational activities. The centers for disease control and prevention estimates that as many as three million nine hundred thousand sports-related and recreation-related concussions occur in the United States each year. A concussion is caused by a blow or motion to the head or body that causes the brain to move rapidly inside the skull. The risk of catastrophic injuries or death are significant when a concussion or head injury is not properly evaluated and managed.
(b) Concussions are a type of brain injury that can range from mild to severe and can disrupt the way the brain normally works. Concussions can occur in any organized or unorganized sport or recreational activity and can result from a fall or from players colliding with each other, the ground, or with obstacles. Concussions occur with or without loss of consciousness, but the vast majority occurs without loss of consciousness.
(c) Continuing to play with a concussion or symptoms of head injury leaves the young athlete especially vulnerable to greater injury and even death. The legislature recognizes that, despite having generally recognized return to play standards for concussion and head injury, some affected youth athletes are prematurely returned to play resulting in actual or potential physical injury or death to youth athletes in the state of Washington.
(2) Each school district's board of directors shall work in concert with the Washington interscholastic activities association to develop the guidelines and other pertinent information and forms to inform and educate coaches, youth athletes, and their parents and/or guardians of the nature and risk of concussion and head injury including continuing to play after concussion or head injury. On a yearly basis, a concussion and head injury information sheet shall be signed and returned by the youth athlete and the athlete's parent and/or guardian prior to the youth athlete's initiating practice or competition.
(3) A youth athlete who is suspected of sustaining a concussion or head injury in a practice or game shall be removed from competition at that time.
(4) A youth athlete who has been removed from play may not return to play until the athlete is evaluated by a licensed health care provider trained in the evaluation and management of concussion and receives written clearance to return to play from that health care provider. The health care provider may be a volunteer. A volunteer who authorizes a youth athlete to return to play is not liable for civil damages resulting from any act or omission in the rendering of such care, other than acts or omissions constituting gross negligence or willful or wanton misconduct.
(5) This section may be known and cited as the Zackery Lystedt law.
[ 2009 c 475 s 2.]
Notes of Decisions
Cited in 8
cases (2 in the last 5 years), 2016–2025 · leading case: Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016).
Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016). “RCW 28A.600.190. The purpose of the Zackery Lystedt Law is to reduce the risk of injury or death to youth athletes who suffer concussions.”
Newman v. Highland Sch. Dist. No. 203, 381 P.3d 1188 (Wash. 2016). “Newman sued Highland for negligence in violation of the Lystedt law, RCW 28A.600.190, which requires the removal of a student athlete from competition or practice if he or she is suspected of having a concussion.”
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
Hector Martinez & Jolayne Houtz, V. Washington State Univ. (Wash. Ct. App. 2025). “2d at 669 (citing RCW 28A.600.190). Under the Lystedt law: Each school district’s board of directors shall work in concert with the Washington interscholastic activities association to develop the guidelines and other pertinent information and forms to inform and educate…”
Newman v. Highland Sch. Dist. No. 203 (Wash. 2016). “Newman sued Highland for negligence in violation of the Lystedt law, RCW 28A.600.190, which requires the removal of a student athlete from competition or practice if he or she is suspected of having a concussion.”
Haley A. Anderson, Apps. v. Snohomish Sch. Dist. No. 201, Res. (Wash. Ct. App. 2020). “It notes that Washington’s Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, which requires youth athletes be removed from play immediately when they are suspected of sustaining a concussion or head injury, applies only to student athletes.”
Ingram v. United States Ex Rel. Dep't of the Interior, 678 F. App'x 614 (9th Cir. 2017). “The Ingrams argued, at trial and on appeal, that Chief Leschi employees breached both their common law duty and duty under the Zackery Lystedt law by permitting Dwight to play in the fall 2011 football season and by failing to remove him from the September 10, 2011 game after he…”
Keep Kids Safe, V. King Cnty. (Wash. Ct. App. 2024). “2d at 677 (alterations in original) (quoting RCW 28A.600.190(1)(a), (c)). The court implied a right of action because, despite articulating these clear concerns, the statute did not provide a remedy.”
— Wash. Rev. Code § 28A.600.190(1)(a) — 2 cases
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
Keep Kids Safe, V. King Cnty. (Wash. Ct. App. 2024). “2d at 677 (alterations in original) (quoting RCW 28A.600.190(1)(a), (c)). The court implied a right of action because, despite articulating these clear concerns, the statute did not provide a remedy.”
— Wash. Rev. Code § 28A.600.190(1)(c) — 1 case
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
— Wash. Rev. Code § 28A.600.190(2) — 3 cases
Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016). “RCW 28A.600.190. The purpose of the Zackery Lystedt Law is to reduce the risk of injury or death to youth athletes who suffer concussions.”
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
Hector Martinez & Jolayne Houtz, V. Washington State Univ. (Wash. Ct. App. 2025). “2d at 669 (citing RCW 28A.600.190). Under the Lystedt law: Each school district’s board of directors shall work in concert with the Washington interscholastic activities association to develop the guidelines and other pertinent information and forms to inform and educate…”
— Wash. Rev. Code § 28A.600.190(3) — 4 cases
Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016). “RCW 28A.600.190. The purpose of the Zackery Lystedt Law is to reduce the risk of injury or death to youth athletes who suffer concussions.”
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
Ingram v. United States Ex Rel. Dep't of the Interior, 678 F. App'x 614 (9th Cir. 2017). “The Ingrams argued, at trial and on appeal, that Chief Leschi employees breached both their common law duty and duty under the Zackery Lystedt law by permitting Dwight to play in the fall 2011 football season and by failing to remove him from the September 10, 2011 game after he…”
Hector Martinez & Jolayne Houtz, V. Washington State Univ. (Wash. Ct. App. 2025). “2d at 669 (citing RCW 28A.600.190). Under the Lystedt law: Each school district’s board of directors shall work in concert with the Washington interscholastic activities association to develop the guidelines and other pertinent information and forms to inform and educate…”
— Wash. Rev. Code § 28A.600.190(4) — 2 cases
Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016). “RCW 28A.600.190. The purpose of the Zackery Lystedt Law is to reduce the risk of injury or death to youth athletes who suffer concussions.”
Swank v. Valley Christian Sch. (Wash. 2017). “93282-4 We must decide whether Washington's Zackery Lystedt Law (Lystedt law), RCW 28A.600.190, gives rise to an implied cause of action.”
— Wash. Rev. Code § 28A.600.190(l)(c) — 1 case
Donald R. Swank v. Valley Christian Sch., 374 P.3d 245 (Wash. Ct. App. 2016). “RCW 28A.600.190. The purpose of the Zackery Lystedt Law is to reduce the risk of injury or death to youth athletes who suffer concussions.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.