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National Football League Players Association v. National Football League Management Council

March 26, 2009

THE NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, PETITIONER,
v.
THE NATIONAL FOOTBALL LEAGUE MANAGEMENT COUNCIL, RESPONDENT.



The opinion of the court was delivered by: Honorable Paul A. Crotty, United States District Judge

OPINION & ORDER

Petitioner National Football League Players Association ("NFLPA") petitions to confirm a 2007 labor arbitration award ("the Award") and to enter judgment thereon. The arbitration award arises from a dispute between the NFLPA and the Respondent National Football League Management Council ("NFL Management Council").*fn1 The Award interpreted the Collective Bargaining Agreement ("CBA") and the standard NFL Player Contract as to the treatment of workers' compensation payments made to injured players.

NFL Management Council opposes NFLPA's petition on two grounds. First, it claims that the Court lacks jurisdiction to confirm the award under the Labor Management Relations Act ("LMRA") because NFLPA has failed to demonstrate the existence of a case or controversy making confirmation necessary. Second, NFL Management Council argues that confirmation is inappropriate because the Award is not "final and binding."

BACKGROUND*fn2

On May 17, 2005, the NFLPA filed a grievance against the Buffalo Bills and New York Jets on behalf of two injured players, Steve Harvey and David Alexander. The Bills and Jets had claimed offsets for the entire amount of workers' compensation benefits they paid to Harvey and Alexander-i.e., the Bills and Jets claimed a "dollar-for-dollar" offset. The NFLPA argued that a dollar-for-dollar offset deprived injured players of certain benefits to which they were otherwise entitled. The NFLPA contended that under the terms of the CBA and the NFL Player Contract, teams are only entitled to a limited offset for the amount of workers' compensation benefits due and payable during the period of time in which a player is deemed to be entitled to his salary under his contract-i.e., a "time offset." The monetary spread between dollar-for-dollar offsets and time offsets is significant.

On September 15, 2005, the NFLPA brought a similar grievance action against the Carolina Panthers on behalf of players Charles Smith, Dusty Renfro, Michael Swift and Jason Peter. Again, the NFLPA argued that the Panthers' claimed dollar-for-dollar offset was inappropriate and that they were entitled only to a time offset.

For the purpose of arbitration pursuant to the CBA, the NFLPA's grievances against the Bills, Jets, and Panthers were consolidated. On January 10, 2006, the parties participated in an arbitration hearing in New York.

On October 10, 2006, prior to the arbitration decision, the NFLPA and NFL Management Council agreed to settle the claims of the individual players as part of a broader agreement to modify the CBA. In addition, the parties agreed that the arbitration decision (which had yet to be made) could not be used as precedent in future disputes until the CBA reached its "Final League Year," which the parties agreed would be 2010.

The arbitrator issued the Award on February 14, 2007. Pursuant to an earlier agreement, the Award was not unsealed and delivered to the parties until June 6, 2007. The Award found in favor of the NFLPA and held that the teams were only entitled to a time offset of workers' compensation payments, and not the dollar-for-dollar offset which the NFL Management Council sought.

NFLPA commenced the current action on April 16, 2008, by filing their original Petition to confirm the Award "pursuant to the Federal Arbitration Act." Following a pre-motion conference before this Court, NFLPA filed its Amended Petition "under and pursuant to" Section 301 of the LMRA.

DISCUSSION

First, the NFL Management Council opposes the confirmation of the Award and, pursuant to Rules 12(b)(1) and (b)(6), moves to dismiss for lack of subject matter jurisdiction and failure to state a claim. Specifically, Respondent argues that there is no present case or controversy since the arbitrated dispute has already been resolved and the Award, by its terms, is not effective until 2010, and may never be effective. Second, NFL Management Council argues that NFLPA fails to state a claim under the LMRA because the Award is not "final and binding."

I. Whether confirmation of the Award requires a "case or controversy"

The Management Council maintains that arbitration awards under the LMRA cannot be confirmed unless the petitioner alleges the existence of a case or controversy. In order to satisfy the case or controversy requirement, the petitioner must demonstrate that the respondent undertook some action that was inconsistent with the arbitrator's award. In the present case, NFLPA can demonstrate no more than a "hypothetical grievance" because the underlying disputes with the players have been settled, NFL ...


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