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Keywords

contractbreach of contractplaintiffdefendantinjunctiontrustantitrust
contractplaintiffdefendanttrustantitrust

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Nassau Sports v. Peters, 352 F.Supp. 870, 70 Lab.Cas. P 13,343, 1973-1 Trade Cases P 74,311

Facts

The plaintiff, Nassau Sports, acquired the rights to Garry Peters' services through an assignment from the Boston Bruins, with whom Peters had a contract that included a reserve clause. Peters, however, signed a contract with the Metropolitan Hockey Club while still under the Bruins' contract, which led to the plaintiff seeking an injunction to enforce its rights. The plaintiff had paid $300,000 for the right to Peters' services for the 1972-73 season and argued that Peters' actions constituted a breach of contract.

Plaintiff's claim of exclusive contract rights to Peters' services is based upon the following substantially undisputed facts.

Issue

The main legal issue was whether the plaintiff had enforceable rights to Garry Peters' services under the contract, and whether the enforcement of those rights would violate antitrust laws.

The contesting clubs, plaintiff and defendant here, unlike their respective leagues, stand on a more equal footing.

Rule

The court applied principles of contract law, particularly regarding the enforceability of options and reserve clauses in personal services contracts, and considered the implications of antitrust law on such contracts.

The primary requisite for enforcing either the contract or the option clause is that the player be an athlete of exceptional talent.

Analysis

The court found that the reserve clause in Peters' contract with the Bruins created an enforceable option for the plaintiff to retain Peters' services for the 1972-73 season. The court noted that the defendants' arguments regarding antitrust illegality did not sufficiently undermine the plaintiff's contractual rights, and that the balance of hardships favored the plaintiff, who had made a significant financial investment in acquiring those rights.

The court's research, necessarily preliminary at this stage, indicates that two approaches are utilized by Massachusetts courts in the construction and enforcement of contracts.

Conclusion

The court granted the preliminary injunction, prohibiting Peters from playing for the Metropolitan Hockey Club during the 1972-73 season, affirming the plaintiff's contractual rights.

In sum, Peters' option commitment for the current season is held to be a clearly established contract right in favor of plaintiff which must prevail over unproved and questionable defensive claims that such an option violates the antitrust laws.

Who won?

The plaintiff, Nassau Sports, prevailed in the case because it successfully demonstrated a prima facie contract right enforceable by injunction, and the court found no compelling antitrust violation that would bar enforcement of the contract.

The balance of hardships tips decidedly toward the plaintiff in this case at this time.

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