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National Football League Players v. National Football League

January 5, 2011

NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, ON ITS OWN BEHALF AND ON BEHALF OF BRUCE MATTHEWS,
PLAINTIFF,
v.
NATIONAL FOOTBALL LEAGUE MANAGEMENT COUNCIL, AND TENNESSEE TITANS,
DEFENDANTS.



The opinion of the court was delivered by: Honorable Janis L. Sammartino United States District Judge

ORDER (1) GRANTING DEFENDANTS' MOTION TO CONFIRM ARBITRATION AWARD AND (2) DENYING PLAINTIFF'S MOTION TO VACATE ARBITRATION AWARD (Doc. Nos. 23 & 24.)

On August 5, 2010, an arbitrator ruled that Bruce Matthews could pursue a workers' compensation claim in California but that the claim must proceed under Tennessee law, if at all. In response, the National Football League Players Association (NFLPA or Plaintiff) brought suit on behalf of itself and Matthews to vacate the arbitration award. Presently before the Court is Defendants National Football League Management Council (NLFMC) and Tennessee Titans' (collectively Defendants) motion to confirm arbitration award (Doc. 23 (Mot. to Confirm) and Plaintiff's motion to vacate arbitration award. (Doc. 24 (Mot. to Vacate).) After consideration, the Court finds that the arbitrator did not manifestly disregard the law and the award is not contrary to public policy. Thus, the Court GRANTS Defendants' motion to confirm arbitration award and DENIES Plaintiff's motion to vacate arbitration award. The arbitration award granted on August 5, 2010, is CONFIRMED.

BACKGROUND

Bruce Matthews played football in the National Football League (NFL) from 1983 to 2002. (Compl. ¶ 12.) As a member of the NFL, Matthews was bound by a collective bargaining agreement (CBA) negotiated between the NFLMC, on behalf of the teams, and the NFLPA, on behalf of all NFL players. (Compl. ¶ 19.) The CBA provides that all disputes involving the CBA or the player contract be submitted to final and binding arbitration. (See Compl. ¶ 18;Mot. to Confirm, Declaration of Daniel Nash, Ex. A at Art. IX, Sec. 1.)

During his NFL career, Matthews was employed by the Houston Oilers and its successor in interest, the Tennessee Titans. (Doc. 9 at 9--10.) Matthews' contract with the Titans stated that "all issues of law, issues of fact, and matters related to workers compensation benefits shall be exclusively determined by and exclusively decided in accordance with the internal laws of the State of Tennessee without resort to choice of law rules." (Id. at 10.)

Approximately five years after he left the NFL, Matthews filed a workers' compensation claim in California. (Id.) This ran contrary to the CBA and Matthews' contract with the Titans, and the Titans and the NFLMC filed a grievance against Matthews for "improper[ly] filing and pursuing claims . . . in violation of [Matthews'] NFL Player Contract." (Compl., Ex. A at 2.)

The grievance was arbitrated. At issue was whether Matthews violated his player contract with the Titans by "filing a claim for workers' compensation benefits in California and requesting that the claim be processed under California law." (Id.) On August 5, 2010, the arbitrator found that Matthews violated his player contract. The arbitrator issued an arbitration award forcing Matthews to proceed under Tennessee law:

[Matthews] is not precluded under Paragraph 26D from filing his workers compensation claim in California. However, [Matthews] is required to proceed under Tennessee law, and accordingly shall cease and desist from attempting to persuade the California tribunals to apply California law in violation of Paragraph 26D of the Player's Contract. Further, under this order [Matthews] is required to withdraw from the California proceeding, should the California tribunals ultimately deny the application of Tennessee law. (Id. at 18.)

Unsatisfied with the arbitration award, Plaintiff filed suit, requesting the Court vacate the arbitration award pursuant to § 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. § 185. After the relevant pleadings had been filed (Docs. 9 & 19), the parties filed the dueling motions at hand. Defendants' motion argues that the arbitration award should be upheld. And like clockwork, Plaintiff's argues the opposite.

JURISDICTION AND LEGAL STANDARD

"Section 301 of the Labor Management Relations Act authorizes the district courts to enforce or vacate an arbitration award entered pursuant to a collective bargaining agreement." Sheet Metal Workers' Int'l Ass'n Local Union No. 359 v. Madison Indus., Inc., of Ariz., 84 F.3d 1186, 1190 (9th Cir. 1996). The review is limited and deferential, however. Id. at 1190. In reviewing an award, this Court does not sit to hear claims of factual or legal error. S. Cal. Gas Co. v. Utility Workers Union of Am., Local 132,265 F.3d 787, 792 (9th Cir. 2001). Instead, the Court's task is "to review the procedural soundness of the arbitral decision." Haw. Teamsters and Allied Workers Union, Local 996 v. United Parcel Serv., 241 F.3d 1177, 1180--81 (9th Cir. 2001).

Nonetheless, in a narrow set of situations, the Court may vacate an arbitration award. "Vacatur of an arbitration award under § 301 of the LMRA is warranted: (1) when the award does not draw its essence from the collective bargaining agreement and the arbitrator is dispensing his own brand of industrial justice; (2) where the arbitrator exceeds the boundaries of the issues submitted to him; (3) when the award is contrary to public policy; or (4) when the award is procured by fraud." S. Cal. Gas Co., 265 F.3d at 792--93.

An arbitration award may also be vacated because of the arbitrator's "manifest disregard of the law." Comedy Club, Inc. v. Improv West Assocs., 553 F.3d 1277, 1289 (9th Cir. 2009). The Court notes, however, it is not clear this basis for vacatur is available in § 301 reviews. The "manifest disregard ground for vacatur is shorthand for a statutory ground under the [Federal Arbitration Act], specifically 9 U.S.C. § 10(a)(4)." Id. at 1290. And the Ninth Circuit has not resolved the issue whether the Federal Arbitration Act (FAA) speaks to suits brought under § 301. See New United Motor Mfg., Inc. v. United Auto Workers Local 2244, 617 F. Supp. 2d 948, 954 n.6 (N.D. Cal. 2008). Nonetheless, the FAA is often used as a guide when forming the federal common law of labor arbitration under § 301. Id. Thus, this Court will assume, without deciding, that the "manifest disregard of the law" basis for vacatur is available in § 301 actions.

ANALYSIS

The August 5 arbitration award allowed Matthews to file a workers compensation claim in California. But it required that the claim be adjudicated under Tennessee law, if at all. The question before the Court is whether the award should be vacated. Procedurally, the Court is faced with a motion to vacate and a motion to confirm. But given the Court's posture on review, the null result is confirmation of the award. The onus rests on Plaintiff to establish a basis for vacatur. United Food & Commercial Workers Int'l Union, Local 588 v. Foster Poultry Farms, 74 F.3d 169, 174 (9th Cir. 1995).

Plaintiff makes three arguments for overturning the arbitration award. First, Plaintiff argues that the award is contrary to California law and public policy. (Mot. to Vacate at 6.) Second, Plaintiff argues that the award is contrary to federal labor law. (Id. at 9.) And finally, Plaintiff ...


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