776 F.Supp.3d 349
D.S.C.2025Background
- Alonzo E. Adams, representing the estate of Phillip Adams (decedent), filed a negligence and wrongful death lawsuit against NFL, NFL Properties, LLC, and South Carolina State University (SCSU) in South Carolina state court.
- Adams alleges that Phillip Adams, a former football player, suffered repeated head trauma during his career with both SCSU and several NFL teams, resulting in Chronic Traumatic Encephalopathy (CTE) and his eventual suicide.
- The NFL defendants, with SCSU’s consent, removed the case to federal court, claiming federal question jurisdiction based on preemption by § 301 of the Labor Management Relations Act (LMRA).
- Adams moved to remand the case back to state court, arguing his claims are based solely on state law and do not require interpretation of the NFL's collective bargaining agreements (CBAs).
- The NFL defendants filed motions to dismiss, which became moot once the court ruled on the remand motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal question jurisdiction (preemption) | Claims arise under state law, not CBAs, no federal jurisdiction | Claims require CBA interpretation, thus preempted by §301 | No federal jurisdiction; case remanded to state court |
| Duty owed by NFL outside CBAs | NFL owes ordinary duty of care under SC common law | Duties are defined only within CBAs | NFL may owe common law duty; CBA terms not controlling |
| Dependence on Spotter Program | Program independent of CBAs; created after CBAs | Spotter duties arise from or are intertwined with CBA | Spotter Program duties are independent of CBAs |
| Use of evidence outside complaint | Whole record (including Spotter Program) can be considered | Only complaint matters; post-removal arguments improper | Courts can consider entire record for removability |
Key Cases Cited
- Caterpillar Inc. v. Williams, 482 U.S. 386 (1987) (plaintiff is master of the complaint and can avoid federal jurisdiction by relying exclusively on state law)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (preemption occurs only if state law claims are substantially dependent on CBA interpretation)
- Gully v. First Nat’l Bank, 299 U.S. 109 (1936) (federal jurisdiction requires a federal question on the face of the well-pleaded complaint)