Haywood v. University of Pittsburgh
2013 U.S. Dist. LEXIS 140263
| W.D. Pa. | 2013Background
- Haywood sues the University of Pittsburgh in a diversity action alleging (1) breach of a written employment contract’s liquidated damages provision, (2) breach of an alleged oral buyout agreement with Miami University, and (3) due process claims under 42 U.S.C. § 1983 (the latter dismissed early).
- Haywood was hired as Pitt’s head football coach under a written contract expiring January 15, 2016, with a just-cause termination provision and liquidated damages if terminated without just cause.
- The University could terminate for just cause under the contract, while confidentiality provisions survived termination; an oral buyout agreement allegedly promised to pay out Haywood’s Miami University contract.
- After Haywood’s December 31, 2010 arrest, Pitt’s leadership gathered information and ultimately terminated Haywood on January 1, 2011 for just cause; a press release and a January 4, 2011 letter formalized the termination.
- There is disputed testimony about whether Cochran and Elias orally notified Haywood of termination on January 1, 2011 and whether that oral notice alone constituted a termination; the court later held termination occurred no later than the January 1 press release or January 4 letter.
- The court granted Pitt summary judgment on Haywood’s claim for breach of the written contract (count A) and for breach of the oral agreement (count B) because, among other things, the contract’s just-cause termination barred damages and the oral buyout did not survive just-cause termination; the confidentiality counterclaim was resolved in Pitt’s favor to Haywood’s detriment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Breach of written contract: just-cause termination and damages | Haywood asserts lack of good-faith investigation tainted the just-cause finding | University had sole discretion to determine just cause and acted reasonably | University entitled to summary judgment; no damages to Haywood |
| Breach of oral agreement to buy out Miami contract | Oral buyout existed independent of the written contract | Parol evidence bars oral terms; but in any event surviveability is limited | Parol evidence admissible; but just-cause termination terminated all obligations, so no damages from the oral agreement |
| Breach of confidentiality by Haywood; damages | Disclosures were confidential and caused damages | Disclosure was publicly available information; no breach | University counterclaim cannot be established; Haywood did not breach; counterclaim denied; separate damages discussion reserved for nominal damages if breach proved |
Key Cases Cited
- Ware v. Rodale Press, Inc., 322 F.3d 218 (3d Cir. 2003) (elements of contract claim; damages requirement)
- Berwick Hotel Co. v. Vaughn, 150 A.2d 613 (Pa. 1930) (notice of termination must be clear and unambiguous)
- Int'l Milling Co. v. Hachmeister, Inc., 110 A.2d 186 (Pa. 1955) (integration vs. admission exception; timing of admissions)
- Yocca v. Pittsburgh Steelers Sports, Inc., 854 A.2d 425 (Pa. 2004) (parol evidence; integration clause; admission exception)
- Hess v. Gebhard & Co. Inc., 808 A.2d 912 (Pa. 2002) (reasonableness of confidentiality covenants; legitimate interests)