Eller v. National Football League Players Association, 0:11-cv-02623

Background

This is a consolidated action in which retirees sue the NFLPA, its executive director, and two individual players (Brady and Vrabel) after the 2011 CBA, alleging misrepresentation, fiduciary breach, and interference with prospective economic advantage.
The District of Minnesota previously handled related Brady and Eller I actions, including mediation ordered by the court that was confidential.
The 2011 CBA resolved retiree benefits in a way plaintiffs claim was improper negotiated by active players with the League, and the League’s obligation to retirees was not the same as a contract with retirees.
Plaintiffs seek declaratory relief and damages based on alleged sham decertification, settlement negotiations, and interference with retirees’ prospective economic interests.
The complaint in the present action drops antitrust claims and targets the NFLPA, Smith, Brady, and Vrabel, while the League is no longer a defendant.
Defendants move to dismiss arguing lack of legal duty, preemption, and that the relief sought is not justiciable or properly pled.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the interference claim is viable	Eller II alleges intentional interference with prospective economic advantage by active players negotiating with the League.	No Minnesota tort supports such interference here; no existing contract and no showing of improper interference.	Interference claim not viable; interference not shown to be improper.
Whether a fiduciary duty existed due to Smith's statements	NFLPA owed a fiduciary duty to retirees based on Smith’s comments and representation in the Brady litigation.	No fiduciary relationship; active and retired players had conflicting interests and no trust-based duty; Smith’s statement did not create a fiduciary duty to retirees.	No fiduciary duty; claim failed as a matter of law.
Whether the declaratory relief claims are justiciable	Declarations about the 2011 CBA and who could represent retirees are needed.	No genuine dispute; retirees are not employees; relief would in substance modify the CBA.	Declaratory relief claims not justiciable; relief inappropriate.
Whether the action should be amended or joined with necessary parties	Leave to amend should be granted to address deficiencies and potentially join the League.	Amendment would be futile; League not properly joinable as necessary party to the asserted claims.	Leave to amend denied; amendment would be futile.
Whether state-law claims are preempted or otherwise barred	Plaintiffs rely on state-law theories (tortious interference, fiduciary duty) not preempted by LMRA.	Claims are preempted or not viable under the governing law; court need not reach preemption if other grounds dispose of claims.	Court disposed of claims on other grounds; preemption not reached as dispositive.

Key Cases Cited

United Wild Rice, Inc. v. Nelson, 313 N.W.2d 628 (Minn. 1982) (recognizes interference with non-contractual relations and prospective advantage)
Witte Transportation Co. v. Murphy Motor Freight Lines, Inc., 193 N.W.2d 148 (Minn. 1971) (interference with non-contractual business relationships; broad tort scope)
Wild v. Rarig, 234 N.W.2d 775 (Minn. 1975) (interference with contract and business relationships; discusses prospective advantage)
Allied Chem. & Alkali Workers of America v. Pittsburgh Plate Glass Co., 404 U.S. 157 (U.S. Supreme Court 1971) (labor-related exemption and interpretation in labor relations context)
Hope v. Klabal, 457 F.3d 784 (8th Cir. 2006) (fiduciary duty principles in absence of explicit fiduciary relationship)
Toombs v. Daniels, 361 N.W.2d 801 (Minn. 1985) (fiduciary duties require recognized relationship; not present here)