Los Angeles Rams Football Club v. Cannon

Billy Cannon (defendant) was a standout college football player whose collegiate career was slated to end with the January 1, 1960, Sugar Bowl. However, Cannon would be ineligible to play in that game if he turned professional before the game. Depending on the outcome of a coin flip, the Los Angeles Rams Football Club (club) (plaintiff) held the first pick in the college-player draft of the National Football League (NFL). The club wished to draft Cannon if it won the coin flip, but it wanted to ensure that Cannon was amenable to playing for it. Accordingly, Pete Rozelle (the club’s then-general manager) spoke and met with Cannon and his college coach before the draft. In those discussions, Rozelle said that the club was willing to sign Cannon to a three-year contract over three years and that it would do nothing to jeopardize Cannon’s eligibility for the Sugar Bowl. The club won the coin toss and drafted Cannon. Several hours later, Rozelle and Cannon (who was unaccompanied by counsel or another advisor) signed purported contracts for Cannon to play for the club in 1960, 1961, and 1962, and Cannon accepted checks for $10,000 and $500, which he neither endorsed nor cashed. The club did not announce that it signed Cannon, and Rozelle promised not to announce anything until after the Sugar Bowl. The purported contracts stated that they would become valid “only when, as and if” approved by the NFL commissioner. Rozelle submitted only the 1960 document to the commissioner on December 1, which the commissioner apparently approved the same day. However, after discussions with a member of the American Football League, an NFL competitor, Cannon informed the club on December 30 that he no longer wished to play for it and returned the club’s checks. The club sued Cannon, seeking an injunction prohibiting Cannon from playing professional football for another team without its consent and a declaration that the documents the parties signed were valid contracts. Cannon responded that the 1960 document was not a valid contract because the parties never mutually assented to a contract for just one year and that the 1961 and 1962 documents were invalid because the commissioner never approved them.