In May, a WNBA matchup between the Chicago Sky and the Indiana Fever, Sky star Angel Reese was reportedly targeted with racial slurs from fans in the crowd. This has led to the league's investigation and major discussion on how such situations should be handled. Though no formal outcome has occurred, the incident forces us to consider imperative questions: What obligations do leagues and arenas have to protect players from targeted abuse by fan bases? Where is the line between fans expressing emotion and engaging in actual harassment? Do we need clearer rules and/or stronger protections to ensure athletes feel safe and respected while executing their jobs?

A Rivalry Set by the Media

Anyone who knows about women’s basketball knows the rivalry between Caitlyn Clark and Angel Reese. Though there is competitiveness on the court, both Clark and Reese have stated how their so-called “rivalry” is more media-driven than personal.

This media framework has allowed for the WNBA to receive more attention. However, this attention comes with consequences. In the 2023 NCAA Women’s Basketball Championship where Reese’s LSU defeated Clark’s Iowa, Reese made gestures towards Clark where she pointed to her ring finger once it was known that LSU would win the title. Reese was heavily criticized after this for “unsportsmanlike conduct” even though Clark made a similar gesture earlier in the tournament Since then, the media has fueled this storyline casting these two players against each other for their final colligate season in 2024 and into the WNBA.

What could have remained a typical sports rivalry was instead turned into a larger cultural conversation with racial underliers. This has become one where Reese, a black female, is often cast as the “villain” in contrast to Clark, a white female, as the “hero.” That framing does not just exist in headlines or highlight reels, it shapes how fans view and treat these players, both online and in person. As we saw in the recent game between the Chicago Sky and Indiana Fever, it can fuel real-world incidents that cross the line from fandom into harassment. This media-fueled rivalry has only intensified as these two players begin their second season, escalating to something that is beyond the game of basketball.

Just A “Basketball Play”

The play that sparked the investigation happened in the third quarter of the game. Clark jumped and reached over Reese’s head for the basketball just as Reese was going up for a wide-open shot. The contact appeared deliberate, causing Reese to fall to the floor and prompting a confrontation between the two players. Officials responded by assessing Clark with a flagrant foul and Reese with a technical foul. While Clark later explained her actions and Reese called it simply “a basketball play,” Reese faced significant criticism from fans, including racially motivated comments.

The reaction to this “basketball play” is a prime example of how race plays a major role in how the media and fans interpret players. Clark and Reese are two very competitive and talented players, yet Reese often receives backlash for her “attitude” while Clark is praised for her “competitive edge.” This difference is not just about perceptions. Rather, it impacts how fans treat players and influences how sporting leagues handle misconduct. The biases that have occurred through this “rivalry” are a key example of how fan behavior crosses the line into harassment or abuse, especially targeted attacks like racial slurs. This raises serious questions about the duty of care owed to players and the measures leagues must take to protect them from these occurrences.

Legal Protections for Players

We often forget that star athletes are employees who have a right to a safe and harassment-free workplace under the law. Just as any profession requires, athletes have the right to perform their jobs without being subjected to abuse, discrimination, or hostile environments. Though their workplace is in arenas with millions watching while most of us are in a more traditional workplace setting, it does not diminish their right to a safe environment. Clark and Angel receiving essentially the opposite treatment reflects how public bias can transition into workplace hazards. This drastic disparity shows why professional leagues must actively monitor the fan behavior of fans to protect players before it becomes out of control.

Workplace safety laws, such as those enforced under the Occupational Safety and Health Act (OSHA) and Title VII of the Civil Rights Act, require employers to provide an environment free from harassment. For professional sports leagues and teams, this means taking reasonable steps to prevent and address abusive conduct, including harassment by fans during games. While it is challenging to control every fan in a stadium or arena, leagues are expected to enforce fan conduct policies, remove disruptive individuals, and ensure security measures are in place to protect players. Failure to do so can open the door to legal claims based on negligence or a hostile work environment.

The Freedom of Speech Debate

One argument that may arise is an individual’s First Amendment right. Fans do have the right to express themselves at games, including cheering, jeering, and showing passion. However, the First Amendment does not protect speech that crosses into harassment, threats, or racial slurs. This is especially true in a private venue like a sports arena, where the owner sets the rules of conduct. Courts have generally upheld that venues can limit disruptive or abusive behavior to maintain a safe environment.

Balancing Player Protection and Fan Expressions

This balance between protecting players and respecting fan expression is a delicate line to follow. The Reese incident highlights the need for clear policies and swift enforcement to ensure that athletes can perform their tasks without fear of abuse while fans still can be passionate about their teams. This incident involving Reese is a reminder that professional athletes deserve more than just praise and applause. They deserve protection, respect, and a safe environment to perform their job. As leagues like the WNBA continue to grow in visibility and influence, they face increasing pressure to not only celebrate their stars but to also shield them from harm.

Finding the line between fan passion and harmful hate is challenging, but it is a responsibility the league cannot ignore. Clear policies, consistent enforcement, and a commitment to creating respect both on and off the court are essential to ensure player safety. How the WNBA responds to this event will set a precedent for the future of sports and send a powerful message about the values we want our leagues to uphold for future generations.

Katherine Vescio is a 2L at University of Gonzaga School of Law. She can be found on LinkedIn.