National Football League Management Council v. National Football League Players Association

During a football game, officials discovered that the balls of one team measured below the required minimum inflation pressure. The National Football League (NFL) (defendant) launched an independent investigation, which concluded that employees from one team had deliberately deflated the footballs. The investigation also found that a player was (at a minimum) aware that the employees had deflated the footballs. Based on the investigation, the NFL suspended the player for four games under the collective-bargaining agreement (CBA) between the NFL and the NFL Players Association (NFLPA) (plaintiff). Specifically, the NFL concluded that the player violated the CBA by engaging in “conduct detrimental to the integrity of and public confidence in the game of professional football.” The player, through the NFLPA, timely filed an appeal, which resulted in a hearing. Consistently with the CBA, the NFL commissioner appointed himself to preside over the hearing. The hearing revealed that the player had ordered an assistant to destroy his cell phone the same day as his investigation interview. From that fact, the NFL commissioner drew an adverse inference against the player. The NFL commissioner found that the player had participated in the scheme and obstructed the investigation. Analogizing the deflation of the balls to steroid use (which generally resulted in a four-game suspension for first-time use), the NFL commissioner affirmed the suspension. The NFL sued to confirm the arbitration award. The NFLPA sued to vacate the award because the NFL official had denied the NFLPA’s motions to compel testimony from an NFL official regarding the investigation and to produce documents from the investigation. The NFLPA also claimed that the player lacked adequate notice that (1) the conduct could lead to a suspension, (2) the conduct was analogous to steroid use, (3) the player could be disciplined for others’ malfeasance, and (4) the player could be disciplined for obstructing the investigation. The district court vacated the award. The NFL appealed.