Canadian American Association of Professional Baseball, Ltd. v. Ottawa Rapidz

711 S.E.2d 834 (2011)

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Canadian American Association of Professional Baseball, Ltd. v. Ottawa Rapidz

North Carolina Court of Appeals
711 S.E.2d 834 (2011)

Facts

The Ottawa Rapidz (Rapidz) (defendant) joined the Canadian American Association of Professional Baseball, Ltd. (league) (plaintiff) in May 2008. When it joined the league, the Rapidz agreed to be bound by all of the league’s agreements, including its bylaws. Article 13.2 of the bylaws provided that the league’s board of directors (board)—which was comprised of the directors of the league’s other teams—would resolve disputes between a member and the league. Article 13.2 did not use the word arbitration, but other provisions of the bylaws and league documents did expressly refer to arbitration. The Rapidz committed to playing in the league for the 2008 and 2009 seasons. But at the end of the 2008 season, the Rapidz announced it would not play in 2009. The Rapidz applied to the league to be allowed to voluntarily withdraw, but, after a hearing, the board denied the request. The board instead concluded that the Rapidz made an unsanctioned withdrawal from the league and thus terminated the Rapidz’s membership. The league then brought suit against the Rapidz and others in state court, seeking to confirm the board’s actions as the ruling of arbitrators in an arbitration proceeding. After a removal to federal court and remand to state court, the trial judge entered an order confirming the arbitration and entered judgment in favor of the league based on the arbitration award. The Rapidz appealed, arguing, among other things, that the board’s actions did not constitute an arbitration decision because (1) the board acted pursuant to Article 13.2, which did not refer to arbitration and (2) the board was not an impartial third party. Accordingly, the Rapidz argued, there was no arbitration decision for the trial court to confirm.

Rule of Law

Issue

Holding and Reasoning (Beasley, J.)

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