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National Football League Players Association v. National Football League (Peterson)

831 F.3d 985 (2016)

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National Football League Players Association v. National Football League (Peterson)

United States Court of Appeals for the Eighth Circuit

831 F.3d 985 (2016)

Facts

Adrian Peterson (plaintiff) was a running back in the National Football League (NFL) (defendant). The NFL commissioner suspended Peterson indefinitely and fined him six games’ worth of salary. Peterson’s suspension stemmed from his plea of no contest to a charge of reckless assault on one of his children. The NFL’s collective-bargaining agreement, to which all players were bound, stated that the commissioner had the ability to impose discipline for conduct detrimental to the integrity of football. NFL players’ contracts further stated that the commissioner could reasonably fine a player or suspend him indefinitely. Players were also subject to a personal-conduct policy that described various forms of conduct—including domestic violence—that could lead to discipline. This policy did not set precise terms for punishment. Shortly before Peterson’s no-contest plea, the commissioner sent a letter to all NFL personnel explaining that violations of the personal-conduct policy would be subject to enhanced discipline. The letter announced that a first domestic-violence offense would be subject to a six-week suspension without pay. The National Football League Players Association (the association), on Peterson’s behalf, appealed Peterson’s punishment to an arbitrator. The association argued that the commissioner’s letter constituted a new policy that could not be applied retroactively. The association also argued that the commissioner was bound by the precedent set by previous disciplinary actions. The arbitrator affirmed the punishment. The arbitrator held that the commissioner was not bound by precedent and had broad discretion to increase the magnitude of punishments. The association then petitioned in federal court to have the arbitrator’s decision vacated. The association argued that the commissioner improperly punished Peterson retroactively. The trial court ruled in favor of the association, holding that the commissioner’s letter created a new policy that could not be applied retroactively to previous conduct. The NFL appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

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