BJJ Lawsuits in California: Lessons for Coaches

Chris Martin @bizjitsu at Del Mar Jiu Jitsu club 9/2024 training before interviewing the club owner.

The jiu-jitsu community is standing at a legal crossroads. In the wake of two high-profile California lawsuits—Pereda v. Atos Jiu-Jitsu and Greener v. Del Mar Jiu-Jitsu Club—it’s clear that courts are beginning to scrutinize jiu-jitsu liability more closely than ever before. The recent California Supreme Court ruling in the Del Mar case, in particular, is poised to become a legal blueprint for how future injury claims in our sport may be handled. If you're a coach, instructor, or academy owner, now is the time to pay attention. In this article, we break down what happened in these pivotal cases, why the courts ruled the way they did, what the Supreme Court’s involvement really means for our industry, and—most importantly—how you can start taking control of your gym’s risk profile to lower your risk of similar issues.

What Happened: Two Lawsuits That Rocked the BJJ World.

Case 1: Pereda v. Atos Jiu-Jitsu

On August 15, 2017, Ray attended what was only his tenth training session at the studio he later sued in Long Beach, California. During a 30-minute sparring segment with other students, he sparred with a purple belt and was placed in a chokehold. Following the exchange, Ray reported feeling short of breath, experiencing a limp, and showing signs of confusion—all symptoms noted in the court records. These are potential indicators of an arterial dissection, a serious condition that can lead to a stroke if not promptly treated.

Although he had signed a liability waiver, it didn’t help. Why? The decision hinged on the gym’s failure to supervise and properly match students, which the court deeming an unreasonable increase in risk beyond what’s inherent in jiu-jitsu. After speaking with Ray, it's clear that proper onboarding at this studio along with more thoughtful partner assignments may have prevented the injury—a waiver alone wasn’t enough.

Case 2: Greener v. Del Mar Jiu-Jitsu Club

In this far more publicized case, Jack Greener—another beginner—was paralyzed temporarily after an instructor, Francisco “Sinistro” Iturralde, executed a rolling back take that fractured Greener’s cervical spine and causing strokes.

The March 2023 jury verdict awarded Greener over $46 million, and by mid-2025, that number climbed to $56 million with interest and legal fees.

According to the trial record and reporting from PSBR Law, the instructor admitted he attempted a technique he could not control, on a student who was not experienced enough to safely receive it.

The Supreme Court Stepped In — And Then Stepped Back

Most appeals are rejected in minutes. But not this one.

When the defense team appealed the initial $46M judgment, the California Supreme Court took it seriously—each of the three judges spent over an hour reviewing the case, which is almost unheard of in civil sports injury litigation.

After lengthy deliberation:

• One judge felt the appeal had merit

• One was indifferent

• And the final judge ruled the original verdict should stand

With that split, the verdict stands—and the case is now solidified as precedent.

Let that sink in: the highest court in California just affirmed that instructors and gym owners can be held financially responsible if their conduct increases risk beyond what's inherent to the sport.

This isn’t just legal trivia—it’s a message to the entire jiu-jitsu world.

The Message Is Clear: Risk Management Must Evolve

As the sport grows, so does the responsibility of those who lead it. It’s not just about having waivers or liability insurance. It’s about building systems that actually prevent harm.

Here’s Where Coaches Must Act Immediately:

1. New Student Enrollment PROCEDURES

A strong risk management plan begins with a thoughtful and structured onboarding process. You can’t treat a first-day white belt like a seasoned brown belt—not in how you coach them, and certainly not in how you integrate them into live training. Every new student should be individually assessed for their experience level, age, physical condition, injury history, and goals. Are they a complete beginner? Are they coming back from surgery? Are they here to compete or just get in shape? These factors determine how you introduce them to the art—and help prevent early injuries that could lead to legal or reputational damage.

Equally important is educating new students on what is and isn’t acceptable behavior on the mat. That means setting clear boundaries: no slamming, no heel hooks, no ego. Make sure they understand that tapping early and training smart is part of the culture. Finally, use a structured curriculum to gradually introduce higher-risk techniques like takedowns, leg locks, or submissions that require fine control. This not only protects the student, it protects the gym and reinforces a professional, safety-first training environment from day one.

2. Coach-Led Pairing Protocols

One of the most important—and most overlooked—ways to reduce injury risk is to take control of how students are paired for sparring. The Pereda v. Atos lawsuit made it clear: mismatched training partners can significantly increase liability. As a coach, it’s your responsibility to ensure that partner assignments aren’t random or left to chance. Failing to do so can lead to preventable injuries and, in the worst cases, open the door to legal consequences for both you and the gym.

Thoughtful pairing isn’t complicated, but it does require intention. Before assigning partners, consider a few key factors: experience level (white belt vs. brown belt), size and weight differences, training temperament, and any known injuries or physical limitations. Even a short conversation—asking “How long have you been training?” or “Do you have any injuries I should know about?”—can go a long way in keeping the round safe.

Taking an active role in partner selection shows leadership, builds student trust, and reinforces a gym culture where safety comes before ego. Over time, this kind of consistency doesn’t just reduce accidents—it raises the overall standard of your academy.

3. Supervise Every Round

Coaches must actively supervise every round of sparring—not simply observe from the sidelines or sit on their cell phones. It’s your job to stay engaged, alert, and ready to step in if a roll starts getting too aggressive or unsafe. Intervention isn’t optional; it’s a core part of preventing injuries and setting a standard. By enforcing a culture where safety takes priority over ego, you protect your students, reinforce trust, and reduce the risk of legal exposure.

4. Create a Culture Shift

This is what really separates successful gyms from dangerous ones. And it starts at the top.

Watch This Video with Coach Rachel from Appalachian Grapplers

In this featured clip, we sit down with Coach Rachael Williams to talk about how her gym goes beyond insurance and builds a safety-first culture.

“We don’t train for medals first. We train for longevity and learning,” Rachael says. “That mindset helps us reduce injury—and that protects everyone, from brand-new white belts to our black belts.”

She explains how their academy focuses on leadership, communication, and accountability to foster safer training environments. It’s proof that creating a thoughtful culture doesn’t weaken your gym—it makes it stronger.

Don’t Count on Your Waiver to Save You

The Del Mar BJJ and Pereda ruling makes one thing crystal clear: a waiver is not a bulletproof shield. It only protects you from risks that are considered “inherent” to the sport—things like accidental bruises, sore joints, or a legitimate submission done with care. But it does not protect you from poor judgment, negligent supervision, reckless coaching behavior, or dangerously mismatched student pairings. If your actions—or your inaction—create a situation that goes beyond the normal risks of jiu jitsu, that waiver won’t save you.

Many coaches and gym owners rely too heavily on waivers, assuming that a signed piece of paper is all they need to avoid liability. But in reality, a waiver is just part of your legal paper trail. And if that trail reveals that you neglected your responsibilities—like allowing an unsafe roll to continue, failing to intervene, or pairing a new student with someone far too advanced—it can actually be used against you in court. Waivers are important, but they’re only one piece of your broader risk management plan. They must be backed by consistent, responsible actions on the mat every single day.

“A gym owner or instructor can’t knowingly let a student face a significantly greater risk than what is typical in a beginner-level jiu-jitsu class, and then hide behind a waiver.” - Perada case court reference.

The Legal Landscape Is Changing — Are You Prepared?

We’ve been tracking legal developments like Pereda v. Atos and Greener v. Del Mar from the beginning, consistently urging gym owners across the country to reevaluate their programs, strengthen student safety protocols, and prepare for an increasingly complex legal environment. These landmark cases are changing how liability is viewed in combat sports, and if you run a jiu-jitsu academy, now is the time to ask some hard but necessary questions:

• “How much coverage is truly enough to protect my gym?”

• “Do I need professional liability for instructors, or is general liability sufficient?”

• “Are we documenting safety protocols in a way that would hold up in court?”

• “Are open mats, seminars, kids’ classes, off-site events, and guest instructors all covered under our current policy?”

These are not just theoretical concerns—they’re real issues with real consequences. And the answers are rarely black and white. Addressing them isn’t just about legal compliance or risk mitigation—it’s also about improving the overall experience for your students, especially new ones. When a new student walks through your doors, they’re placing their trust in your academy. That first experience should be safe, structured, and welcoming, with clear expectations and thoughtful pairings that reduce risk from day one. Building a safer gym isn’t just about protecting yourself from lawsuits—it’s about creating a culture where students thrive and want to stay.

What questions do you still have about The Legal cases?

What questions or concerns do you have about the Pereda and Del Mar lawsuits we’ve been filming and reporting on? As these cases reshape how liability is being interpreted in jiu-jitsu, we want to hear directly from you.

Is there something you’re unclear about? A part of the case you want explained? A detail you wish we’d ask in our interviews with those involved?

Email us your questions now—whether it’s about legal exposure, waivers, instructor responsibilities, or insurance gaps—and we’ll do our best to get you answers straight from the source. We’re having these conversations so the entire community can learn, adapt, and protect what we’ve built.

Final Word: This Is a Wake-Up Call

No one wants to see another Jack Greener or another Ray Pereda. And no coach wants to be the one under fire in the courtroom.

This moment is an opportunity. To reflect. To evolve. To build a safer, stronger, more sustainable sport for everyone.