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contractdamagesinjunctiontrialcorporation
contractdefendantdamagesinjunctionappealtrialcorporation

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Lemat Corp. v. Barry, 275 Cal.App.2d 671, 80 Cal.Rptr. 240

Facts

Lemat Corporation, the owner of the San Francisco Warriors, brought an action against former player Richard F. Barry III for injunctive relief after Barry did not sign a proposed contract for the 1967-1968 season. Barry had previously played for the Warriors and was under a contract that included a renewal option. After receiving the proposed contract, Barry opted to sign with the Oakland Oaks of the ABA instead. Lemat sought a longer injunction and damages, arguing that Barry's actions caused significant financial loss to the team.

These consolidated appeals involve an action for injunctive relief brought by the owner and operator of a professional basketball team, Lemat Corporation (hereafter Lemat), against one of its former players, defendant Richard F. Barry III (hereafter Barry). Lemat appeals from a portion of the final judgment in its favor granting a one-year injunction, contending that it was entitled to injunctive relief for seven years, as well as damages.

Issue

Did the Warriors have the right to enforce a two-year contract with a renewal option against Barry, and were they entitled to injunctive relief beyond one year?

Did the Warriors have the right to enforce a two-year contract with a renewal option against Barry, and were they entitled to injunctive relief beyond one year?

Rule

Under California law, a contract for personal services may not be enforced beyond seven years. A contract that limits a person's ability to follow their vocation must be strictly construed. Injunctive relief can only be granted to prevent future injury and not for damages in addition to that relief.

A contract to render personal service, other than a contract of apprenticeship as provided in Chapter 4 of this division, may not be enforced against the employee beyond seven years from the commencement of service under it. Any contract, otherwise valid, to perform or render service of a special, unique, unusual, extraordinary, or intellectual character, which gives it peculiar value and the loss of which cannot be reasonably or adequately compensated in damages in an action at law, may nevertheless be enforced against the person contracting to render such service, for a term not to exceed seven years from the commencement of service under it.

Analysis

The court found that the contract's renewal option was valid for one additional year, as Barry did not sign the proposed contract. The court emphasized that the Warriors' right to enforce the contract was limited to the terms agreed upon, which did not extend beyond the second year. The court also noted that any damages claimed by Lemat were speculative and could not be awarded in conjunction with the injunction.

The trial court found that the contract here was one of adhesion and as such must be strictly construed against Lemat. Furthermore, any agreement that limits a person's ability to follow his vocation must be strictly construed. Lemat has not cited (nor have we been able to find) a single decision that would support its position. The authorities are to the contrary.

Conclusion

The court affirmed the trial court's judgment, granting Lemat a one-year injunction but denying any further injunctive relief or damages.

Accordingly, the trial court entered its final judgment dated November 6, 1968, enjoining Barry from playing for any other team until September 30, 1968.

Who won?

The prevailing party in this case was Lemat Corporation, as they were granted a one-year injunction against Barry. The court recognized the unique nature of Barry's services and the potential financial impact of his absence from the Warriors. However, the court limited the injunction to one year, adhering to the terms of the contract and California law, which restricts the enforcement of personal service contracts beyond a specified duration.

The prevailing party in this case was Lemat Corporation, as they were granted a one-year injunction against Barry. The court recognized the unique nature of Barry's services and the potential financial impact of his absence from the Warriors. However, the court limited the injunction to one year, adhering to the terms of the contract and California law, which restricts the enforcement of personal service contracts beyond a specified duration.

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