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Oakland Raiders v. National Football League

32 Cal. Rptr. 3d 266 (2005)

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Oakland Raiders v. National Football League

California Court of Appeal
32 Cal. Rptr. 3d 266 (2005)

Facts

The Oakland Raiders (club) (plaintiff) were a member of the National Football League (NFL) (defendant), which was a nonprofit, unincorporated association. The club sued the NFL and its commissioner, Paul Tagliabue (defendant), alleging that they owed it a fiduciary duty (i.e., the duty to act in the club’s best interest) arising from (1) the nature of the parties’ business relationship, which allegedly was analogous to other relationships giving rise to fiduciary duties, and (2) a settlement agreement between the club and the NFL, which Tagliabue signed on the NFL’s behalf. The club further claimed that the NFL and Tagliabue breached their fiduciary duty by discriminating against it. The NFL and Tagliabue denied owing any fiduciary duty to the club, arguing that (1) as a not-for-profit, unincorporated association, the NFL’s relationship with the club was not comparable to the fiduciary relationships the club cited and (2) the NFL’s governing documents, to which all NFL clubs agreed, refuted any fiduciary relationship because they contemplated that the NFL or Tagliabue might take action adverse to the club. The trial court granted summary judgment to the NFL and Tagliabue. The club appealed.

Rule of Law

Issue

Holding and Reasoning (Premo, J.)

Concurrence (Rushing, J.)

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