Collins v. NBPA & Grantham case brief

Collins v. NBPA & Grantham case brief summary
850 F.Supp. 1468 (1991), affirmed per curiam, 976 F.2d 740 (10th
Cir.1992)

CASE SYNOPSIS

Defendant athlete association filed a motion for summary judgment in an action filed against it by plaintiff agent, who alleged that the association's collective bargaining agreement that forbids athletic teams from negotiating with non-certified agents violated §§ 1 and 2 of the Sherman Act, 15 U.S.C.S. §§ 1 and 2, and that the association tortiously interfered with the agent's contracts and prospective business advantage.

CASE FACTS

• The agent had been certified by the athlete association to represent athletes in negotiating the athlete's contracts. 
• The agent voluntarily stopped acting as an athlete agent because of legal action filed against the agent by one of his former clients, which alleged that the agent has mishandled and transferred funds. 
• The agent then allowed his certification to lapse. 
• The agent and athlete settled their lawsuit, and the agent sought recertification. The association granted interim certification to the agent, but later denied recertification. 
• The agent did not seek a review of the association's decision and instead filed an action against them alleging that the association's refusal to allow teams to negotiate with non-certified agents was a violation of antitrust laws. 
• The association sought summary judgment. 

DISCUSSION

• The court found that the association had properly advised the agent of his opportunity to challenge the denial of recertification, that the athlete association's collective bargaining agreement was exempt from antitrust laws, and that recertification of the agent would have been a breach of fiduciary duty the association owed to the athletes.

CONCLUSION

The court granted summary judgment to the athlete association and denied the agent's claims.

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