Eller, et al. v. NFL Players Assoc., et al., No. 12-2487 (8th Cir. 2013)
Annotate this CaseThis case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - National Football League Litigation. In a class action lawsuit brought by retired NFL players against the Players Association, its executive direction and certain of the Brady case plaintiffs asserting the defendants wrongfully barred retirees from the Brady settlement negotiations and agreed to a settlement which provided the retired players with fewer benefits than they could have obtained for themselves, the district court did not err in dismissing the retired players' claims for intentional interference with prospective economic gain as no reasonable jury could find the players had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided by the 2011 CBA; nor did the plaintiffs establish that the Brady plaintiffs improperly interfered with any such expectation.
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