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National Football League Players Ass'n v. Pro-Football, Inc.

Citations: 849 F. Supp. 1; 145 L.R.R.M. (BNA) 2225; 1993 U.S. Dist. LEXIS 18567; 1993 WL 625555Docket: Civ. A. 93-2665

Court: District Court, District of Columbia; December 30, 1993; Federal District Court

Narrative Opinion Summary

In this case, the National Football League Players Association (NFLPA) sought a temporary restraining order (TRO) against Pro-Football, Inc. (Washington Redskins) and the NFL Management Council, aiming to enforce an arbitration award mandating the suspension of all Redskins players, except Terry Orr, for not paying union dues by the stipulated deadline. The dispute hinged on a previous ruling by Judge Thomas D. Horne, who determined that the players' primary employment location was Virginia, thus granting Orr a TRO until early January 1994. Judge Joyce Hens Green of the District Court denied the NFLPA's motion for a TRO, aligning with Judge Horne's findings and the Redskins' arguments. The court applied the standard criteria for a TRO, emphasizing the lack of a substantial likelihood of success on the merits for the NFLPA and the potential for irreparable harm to the Redskins, the public, and third parties. The court highlighted the potential impact on the scheduled game against the Minnesota Vikings, which could lead to significant financial and competitive repercussions. The decision resulted in the denial of the TRO with no stay of the order, and the NFL was allowed to intervene as a party-defendant with the parties' consent. The NFLPA was instructed to notify the court of its intentions by early January 1994.

Legal Issues Addressed

Intervention by Parties in Legal Proceedings

Application: The NFL was allowed to intervene as a party-defendant with the consent of all parties involved, illustrating the procedural aspect of party intervention.

Reasoning: The NFL was permitted to intervene as a party-defendant with the consent of all parties.

Likelihood of Success on the Merits

Application: The court found that the NFLPA did not demonstrate a likelihood of success on the merits, as the arguments presented by the Redskins were more persuasive.

Reasoning: The court concluded that the NFLPA did not demonstrate a likelihood of success and that any potential injury to the NFLPA was outweighed by the possible harm to the Redskins and the broader public interest.

Potential Harm to Third Parties

Application: The court identified potential harm to third parties, including the Minnesota Vikings and their playoff chances, as a factor against granting the TRO.

Reasoning: Additionally, the playoff chances of the Minnesota Vikings and their competitors could be adversely affected if certain Redskins players are suspended, resulting in an uncompetitive game due to either a forfeit or a weakened team.

Public Interest Consideration in TRO

Application: The court considered the broader public interest, noting the potential negative impact on the NFL, the Redskins, and the public due to the scheduled game against the Minnesota Vikings.

Reasoning: Irreparable injury would result to the public, third parties, and the Redskins if the actions in question occur, as stated by the Redskins, the NFL, and John Kent Cooke.

Temporary Restraining Order Criteria

Application: The court applied the standard criteria for granting a TRO, which include a substantial likelihood of success on the merits, irreparable injury without relief, no harm to other parties, and public interest favoring the order.

Reasoning: The criteria for granting a TRO include a substantial likelihood of success on the merits, irreparable injury without relief, no harm to other parties, and public interest favoring the order.