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Brown v. Woolf
United States District Court for the Southern District of Indiana
554 F. Supp. 1206 (S.D. Ind. 1983)
Bob Woolf (defendant) was the agent for professional hockey player Andrew Brown (plaintiff) and negotiated a contract on Brown’s behalf with the National Hockey League’s (NHL) Pittsburgh Penguins for the 1973-74 season. In July 1974, the Penguins offered Brown a guaranteed two-year contract worth $80,000 per year. Woolf advised Brown to reject the offer and, instead, sign with the recently-developed World Hockey League’s (WHL) Indianapolis Pacers. The Pacers offered Brown a five-year guaranteed contract worth $160,000 per season, totaling $800,000. However, financial difficulties plagued the Pacers and they were eventually forced to re-negotiate Brown’s salary with Woolf. Brown ended up collecting just $185,000 of the entire $800,000 on the contract. However, the Pacers agreed to pay Woolf’s 5 percent fee applied to the entire $800,000 contract promise—a total of $40,000. Brown brought suit against Woolf alleging both constructive fraud and breach of fiduciary duty for failing to investigate the Pacer’s financial condition while receiving his entire fee. Woolf filed motions for partial summary judgment and summary dismissal of the suit.
Rule of Law
Holding and Reasoning (Steckler, J.)
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