794 N.W.2d 391
Minn. Ct. App.2011Background
- Appellants Kevin Williams and Pat Williams, NFL players, faced NFL disciplinary suspensions for bumetanide testing under DATWA.
- DATWA governs drug and alcohol testing; bumetanide is not classified as a “drug” under DATWA’s schedules.
- Labs performed A- and B-bottle confirmatory tests solely verifying bumetanide presence, not broader drug testing.
- District court held NFL was a joint employer subject to DATWA notice provisions but found no evidence of DATWA confidentiality violations.
- Court concluded DATWA did not apply to the confirmatory bumetanide testing, thus no basis for notice requirements or permanent injunctive relief.
- Appeal centers on whether the district court properly limited review and whether DATWA applied to the tests at issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does DATWA apply to the confirmatory bumetanide tests? | Williams argues DATWA governs confirmatory testing. | NFL contends bumetanide tests are not DATWA testing. | No; bumetanide not a DATWA drug. |
| If DATWA applies, does it mandate injunctive relief? | DATWA violations require injunctive relief. | Not applicable if DATWA doesn’t govern the tests. | Not reached on appeal; decision rests on DATWA’s inapplicability. |
| What is the proper scope of review on an appeal from a permanent injunction? | Challenge includes damages/fees. | Scope limited to injunction; separate review for damages. | Abuse-of-discretion for injunction; underlying merits reviewed as needed. |
| Is NFL an employer under DATWA for purposes of notice/confidentiality? | NFL is an employer and subject to DATWA. | NFL disputes applicability to the DATWA provisions. | NFL found to be an employer; DATWA applicability limited by test scope. |
| Are the confidentiality provisions of DATWA invoked or satisfied? | NFL violated confidentiality provisions. | District court did not clearly err; evidence insufficient. | Not clearly erroneous; no proven DATWA confidentiality violation. |
Key Cases Cited
- Williams v. Nat'l Football League, 582 F.3d 863 (8th Cir.2009) (preemption not applicable to DATWA claims in the circuit)
- Randolph v. Rodgers, 170 F.3d 850 (8th Cir.1999) (on appeal from permanent injunction, review limited to injunction challenges)
- Sheeran v. Sheeran, 481 N.W.2d 578 (Minn.App.1992) (damages issues reviewed on appeal from judgment)
- Jackel v. Brower, 668 N.W.2d 685 (Minn.App.2003) (abuse-of-discretion standard for injunctions)
- Beardsley v. Garcia, 753 N.W.2d 735 (Minn.2008) (statutory language plain; apply literal meaning)
- Edina Educ. Ass’n v. Bd. of Educ. of Indep. Sch. Dist. No. 273, 562 N.W.2d 306 (Minn.App.1997) (injunctions based on statutes; deference to district court on factual findings)