Miami Dolphins Ltd. v. Williams
United States District Court for the Southern District of Florida
356 F. Supp. 2d 1301 (2005)
- Written by Steven Pacht, JD
Facts
The New Orleans Saints (New Orleans) of the National Football League (NFL) signed Errick L. “Ricky” Williams (defendant) to a contract that included a signing bonus. However, the contract provided that Williams would have to refund approximately $3.3 million of the bonus if he voluntarily elected not to play football at any time between January 31, 2004, and the eighth game of the NFL’s 2004 season. The Miami Dolphins Ltd. (Miami) (plaintiff) acquired Williams from New Orleans before the 2002 NFL season. Miami and Williams entered into a new contract, which provided Williams with the opportunity to earn performance-based bonuses, some of which he earned. The Miami contract stated that Williams would have to refund all incentive bonuses he received from Miami if he refused to play football. Williams’s Miami contract also incorporated by reference the bonus-refund provision of his original New Orleans contract. In July 2004, Williams decided to stop playing football. Miami filed a grievance against Williams and the NFL Players Association (union) (defendant) under the collective-bargaining agreement (CBA) between the NFL and the union, seeking an award ordering Williams to refund Miami approximately $8.6 million (representing a portion of his New Orleans signing bonus and the incentive bonuses Miami had paid him). The arbitrator ruled in Miami’s favor, and Miami filed suit in federal court pursuant to the Federal Arbitration Act to confirm the arbitrator’s award. Williams and the union responded by moving to vacate the award on the grounds that (1) the arbitration award evinced a manifest disregard for Florida law regarding liquidated damages and (2) enforcing the award would violate Florida’s public policy against contract penalties.
Rule of Law
Issue
Holding and Reasoning (Cohn, J.)
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