Boogaard v. National Hockey League

A professional hockey player became addicted to pain medication after receiving a prescription from team doctors. The National Hockey League (NHL) (defendant) placed the player in a substance abuse program under an agreement between the NHL and the players’ union. The substance abuse agreement was incorporated into the collective-bargaining agreement (CBA) between the NHL and the union. After leaving a rehabilitation facility and returning to play, the NHL told the player that he could not use pain medications. But NHL doctors nonetheless prescribed the player medications and did not penalize him when he reported buying medications off the street. Eventually, the player overdosed and died. Len and Joanne Boogaard (plaintiffs), the player’s parents, brought various state claims sounding in negligence as the representatives of his estate. The claims essentially alleged that the NHL breached a duty it owed the player under the substance abuse agreement to cure his addiction. The NHL removed the case to federal court. The district court concluded that § 301 of the Labor Management Relations Act (LMRA) preempted the state claims because the claims were based on rights under the CBA. The district court then dismissed the claims as time-barred by the LMRA. The district court also dismissed the remaining claims on other grounds. The Boogaards appealed.