The United States District Court for the Middle District of Pennsylvania has held that whether a professional football player was within the scope of his employment while on the "free time" granted to players during summer camp was a material issue of fact precluding the granting of the professional team's motion for summary judgment.
Mauk v. Wright, 367 F. Supp. 961 (M.D. Pa. 1973).
Fred R. Brown,
Torts - Master-Servant - Respondeat Superior - "Free Time" as Within the Scope of Employment,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol13/iss2/8