Brocail v. Detroit Tigers, Inc.

Douglas Brocail (plaintiff) was a pitcher for the Detroit Tigers, Inc. (Detroit) (defendant) in 2000. His employment was subject to the standard player contract agreed to by Major League Baseball (MLB) and the MLB players’ union in a collective-bargaining agreement (CBA). Among other things, the CBA governed when Detroit was required to provide a second medical opinion by a specialist in the event that Brocail suffered a baseball-related injury and the terms under which Brocail could be traded to another MLB club. In June 2000, Brocail began experiencing pain in his pitching elbow. Brocail was examined and treated by Detroit’s physicians and a specialist for this problem, and he spent part of the 2000 season on the disabled list. Brocail tried to play in early September but immediately experienced more pain. Brocail underwent surgery in late September, which revealed damage to his elbow that was more significant than expected. In November, Detroit traded Brocail to the Astros. But Brocail suffered a serious elbow injury in April 2001 that kept him from playing at all that season. Brocail did not return to MLB until 2004. Brocail sued Detroit under Michigan law, alleging, among other things, that (1) Detroit’s team doctors were negligent in treating him, (2) Detroit should have provided him with another second opinion by a specialist, and (3) Detroit improperly traded him to the Astros without his consent or by fraudulently inducing him to consent. Detroit moved for summary judgment, arguing, among other things, that the claims were preempted by the federal Labor-Management Relations Act (LMRA) because they required the court to interpret the CBA’s meaning. Brocail responded that Detroit’s duty to provide him with reasonable medical care was created by Michigan’s Workers’ Disability Compensation Act (WDCA), not the CBA, and that his trade-related claims also did not require interpreting the CBA. The trial court granted summary judgment to Detroit. Brocail appealed.