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Keywords

contractdefendantarbitrationmotionleasearbitration clausearbitrator
contractplaintiffarbitrationarbitrator

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Morris v. New York Football Giants, Inc., 150 Misc.2d 271, 575 N.Y.S.2d 1013, 141 L.R.R.M. (BNA) 2343

Facts

Professional football players Joseph Morris and Michael Shuler brought actions against their respective teams, the New York Giants and the New York Jets, claiming entitlement to compensation equal to 10% of their contract amounts after being released prior to the 1990 NFL season. The players had signed individual contracts that included arbitration clauses, which specified that disputes would be resolved by the league commissioner if no collective bargaining agreement (CBA) was in effect. The CBA had expired in 1987, leading to the current dispute over the interpretation of their contracts and the appropriate arbitration process.

This action arises out of a dispute between two professional football players and their former football clubs over the amount of compensation owed to the players for their services in 1990 prior to the start of the football season (1990 pre-season).

Issue

Whether the players' grievances are subject to arbitration under their individual contracts despite the expiration of the collective bargaining agreement.

Whether the players' grievances are subject to arbitration under their individual contracts despite the expiration of the collective bargaining agreement.

Rule

The court held that while the collective bargaining agreement had expired and grievances arising after that date were not subject to arbitration under its terms, the individual player contracts required arbitration of disputes. However, the league commissioner named in those contracts was deemed not neutral, necessitating the appointment of a neutral arbitrator.

Collective bargaining agreement between professional football league and players association was not extended or renewed after it expired in August 31, 1987, so that grievances arising after that date were not subject to arbitration under the terms of the agreement.

Analysis

The court analyzed the arbitration clauses in the players' contracts, determining that they were enforceable despite the expiration of the CBA. It found that the players were sophisticated and had bargaining power, thus the arbitration clauses were not adhesion contracts. However, the court concluded that the league commissioner could not serve as an impartial arbitrator due to potential bias stemming from his prior advocacy for the teams' positions.

Although individual contracts between players and professional football teams called for arbitration of grievance before league commissioner, league commissioner was not unbiased, and neutral arbitrator would have to be substituted; commissioner was selected by and employed by the individual teams, frequently represented the teams in disputes with players and advocated the positions of the owners, and had previously advocated a position in opposition to the position taken by the players in the grievance under dispute.

Conclusion

The court granted the defendants' motion to compel arbitration but appointed a neutral arbitrator to replace the league commissioner due to concerns about bias.

Ordered accordingly.

Who won?

The court ruled in favor of the defendants, the New York Giants and the New York Jets, by compelling arbitration of the players' grievances. The court recognized the necessity of arbitration under the individual contracts while also acknowledging the need for a neutral arbitrator, thus balancing the interests of both parties. The players' claims were not dismissed, but the court ensured that the arbitration process would be fair and impartial.

The court finds that Tagliabue's position as Commissioner, together with his past advocacy of a position in opposition to plaintiffs' position herein, deprive him of the necessary neutrality to arbitrate these claims.

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