Brady v. National Football League
779 F. Supp. 2d 1043
D. Minnesota2011Background
- NFL moved for stay pending appeal of this Court's April 25, 2011 Order enjoining the lockout.
- Order granted Brady plaintiffs preliminary injunctive relief, enjoining the lockout but not other conduct.
- NFL appeals issues include Norris-LaGuardia Act jurisdiction, primary jurisdiction of NLRB, and the nonstatutory labor exemption.
- Court analyzes stay standards under Nken v. Holder and Hilton v. Braunskill, applying a four-factor test.
- Court finds no irreparable harm to NFL, no strong likelihood of success on the merits, and public interest weighs against a stay; motion denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction under Norris-LaGuardia Act | Brady contends Act applies to bar injunction in labor dispute. | NFL argues Act permits district court injunctions in labor disputes and exempts stay. | Court denies stay; Act issues not controlling for this injunction. |
| Primary jurisdiction by NLRB on disclaimer | Bradys rely on disclaimer validity to trigger nonstatutory labor exemption. | NFL asserts NLRB input is necessary before ruling on disclaimer. | Court held ruling on disclaimer was appropriate without NLRB input. |
| Nonstatutory labor exemption scope | Exemption may shield NFL actions; dispute about distance from bargaining. | Exemption applies if actions are sufficiently connected to bargaining; court should defer to NLRB views. | Court determined lockout not a mandatory term and not insulated by exemption; no decision on broader reach. |
| Balance of equities and irreparable harm | Stay would prevent irreparable harm to players; injunction should stand. | Stay prevents irreparable harm to NFL labor rights and public interest in season. | Equities favor Brady plaintiffs; no irreparable harm shown to NFL sufficient to stay. |
| Public interest | Enforce antitrust/Sherman Act protections and avoid lockout-induced antitrust issues. | Public interest favors maintaining collective bargaining processes. | Public interest weighs against a stay; enforce the Court's order. |
Key Cases Cited
- Nken v. Holder, 556 U.S. 418 (U.S. 2009) (strong showing on merits required for stays)
- Hilton v. Braunskill, 481 U.S. 770 (U.S. 1987) (four-factor stay test; not a matter of right)
- Reserve Mining Co. v. United States, 498 F.2d 1073 (8th Cir. 1974) (applies four-factor stay standard)
- Brown v. Pro Football, Inc., 518 U.S. 231 (U.S. 1996) (nonstatutory labor exemption requires distance from bargaining with detailed views)
- New Negro Alliance v. Sanitary Grocery Co., 303 U.S. 552 (U.S. 1938) (limits of Norris-LaGuardia Act applicability in labor disputes)