Assuming it is the same injury, Okung has had problems on that left toe for years now, including going on IR-Designated to Return in 2013 and undergoing off-season surgery. Hopefully, he did not suffer another "turf toe" on the 49ers' dangerous field. That field appears to be so abnormally dangerous that I do not think they would be able to overcome a negligence claim with an assumption of the risk defense.