White v. National Football League

92 F. Supp. 2d 918 (2000)

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White v. National Football League

United States District Court for the District of Minnesota
92 F. Supp. 2d 918 (2000)

Facts

The National Football League Management Council (council) (plaintiff) initiated a special-master proceeding against a National Football League (NFL) club and several player agents (collectively, defendants). The council alleged that the club and agents violated the collective-bargaining agreement (CBA) between the NFL and the players’ union and a stipulation and settlement agreement (SSA) (collectively, contracts) in this litigation. The agents moved to dismiss the proceeding against them because they did not sign the contracts. The contracts provided that they would bind the parties and their representatives and agents. In addition, the contracts required agents to certify that any agreement they negotiated for a player complied with the contracts. However, the CBA also provided that the players’ union “regulates the conduct of agents” and that the union had sole authority to certify agents. The CBA also barred NFL teams from negotiating with uncertified agents. Certified agents expressly agreed to obey the union’s rules, including rules requiring agents to be familiar with the CBA and related governing documents and prohibiting agents from violating union rules or policies. The special master dismissed the agents from the proceeding. Per the special master, the contract language binding the parties’ agents was mere boilerplate that should be discounted. The special master also ruled that the contract-certification provision required agents to comply with the contracts but that the CBA gave the union the exclusive power to regulate agents. The council appealed.

Rule of Law

Issue

Holding and Reasoning (Doty, J.)

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