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Keywords

contractlawsuitplaintiffdefendantarbitrationmotionregulation
contracttortplaintiffdefendantarbitrationregulation

Related Cases

Branion v. Wallace, Not Reported in Fed. Supp., 2017 WL 11633674

Facts

Plaintiff John Marshall Branion, III, a certified Contract Advisor, brought a lawsuit against Defendants Carmen Wallace and Roc Nation Sports, LLC for intentional interference with a prospective economic relationship. Branion alleges that Wallace interfered with his relationship with NFL player Melvin Ingram by using deceptive practices to convince Ingram to sign with Roc Nation instead. The case revolves around whether the claims should be arbitrated under the NFL Players Association's regulations, which both parties are subject to as certified agents.

The Plaintiff alleges that Wallace contacted Ingram while he was represented by the Plaintiff. Wallace encouraged Ingram to terminate the SRA with the Plaintiff and sign an SRA with Wallace as his sole agent, which Ingram did.

Issue

Whether the Plaintiff's claims against the Defendants must be arbitrated under the NFLPA's regulations.

Whether the Plaintiff's claims against the Defendants must be arbitrated under the NFLPA's regulations.

Rule

The NFLPA's arbitration procedure is the exclusive method for resolving disputes arising from the activities of Contract Advisors, as outlined in Sections 5(A)(4) and 5(A)(5) of the NFLPA Regulations. A valid arbitration agreement exists if the dispute falls within the scope of these regulations, which require that certain conditions, such as the filing of a Standard Representation Agreement (SRA), be met for arbitration to be compelled.

This arbitration procedure shall be the exclusive method for resolving any and all disputes that may arise from … (4) Any other activities of a Contract Advisor within the scope of these regulations; (5) A dispute between two or more Contract Advisors with respect to whether or not a Contract Advisor interfered with the contractual relationship of a Contract Advisor and player in violation of Section 3(B)(21). NFLPA Regulations, Dkt. 16, Att. 1, Section 5(A)(4) – (5).

Analysis

The court analyzed whether the Plaintiff's claims fell within the scope of the NFLPA's arbitration provisions. It found that while Section 5(A)(5) did not apply because the Plaintiff did not file the SRA with the NFLPA, Section 5(A)(4) did apply as the dispute arose from Wallace's activities as a Contract Advisor. The court emphasized that the nature of Wallace's actions, which involved fraudulent inducement, directly implicated the integrity and conduct standards set forth in the NFLPA Regulations.

The Court agrees with the Plaintiff that not all disputes between two agents would qualify as activities within the scope of the Regulations or that any actions taken by an agent in his professional capacity would qualify for arbitration. For instance, a tort claim unrelated to the Regulations but that interferes with an agent's income would not necessarily be subject to arbitration because it would not specifically involve the agent's interactions with players, even if it may involve his business as an agent.

Conclusion

The court concluded that the Plaintiff's claims against both Defendants must be arbitrated under the NFLPA's regulations and granted the Defendants' request to compel arbitration.

The Court finds that the Plaintiff's claims against both Defendants must be arbitrated under the terms of the Regulations.

Who won?

The Defendants prevailed in this case as the court granted their motions to compel arbitration. The court found that the Plaintiff's claims fell within the scope of the NFLPA's arbitration provisions, specifically under Section 5(A)(4), which governs the activities of Contract Advisors. The court emphasized the importance of adhering to the arbitration process established by the NFLPA, which both parties had agreed to as certified agents.

The Court finds that the Plaintiff's claims against both Defendants must be arbitrated under the terms of the Regulations. The Court therefore GRANTS the Defendants' request to compel arbitration.

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