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Morio v. North American Soccer League | 501 F. Supp. 633 (1980)

Collective bargaining unions are commonplace in professional sports, and they help to balance the extensive power held by league and team owners. In Morio versus North American Soccer League, the court considered whether a professional sports league may be required through injunctive relief to bargain collectively with a certified players union.

The North American Soccer League was a professional soccer league comprised of over twenty individual soccer clubs. We’ll refer to the soccer league and clubs collectively as the league. In nineteen seventy eight, the National Labor Relations Board certified the North American Soccer League Players Association to serve as the exclusive collective bargaining union for the league’s players. However, the league refused to bargain collectively with the players association and continued to negotiate new contracts with individual players. In those new contracts, the league made a number of unilateral changes, including extending the season, creating and requiring the players to play in a winter soccer season, decreasing team roster sizes, and requiring the players to obtain permission to wear certain footwear.

The players association subsequently filed a charge of unfair labor practices before the board, objecting to the league’s refusal to bargain collectively. The board issued an order directing the league to bargain with the players association. The league appealed to the United States Court of Appeals for the Fifth Circuit, which affirmed the board’s order and denied the league’s petition for rehearing. The league failed to obtain a stay of the Fifth Circuit’s order and continued to disobey the order. The board’s regional director, Winifred Morio, sued the league in federal district court. Morio asserted that the league’s practices violated the National Labor Relations Act and thus sought an injunction to prevent the league from negotiating individual contracts. Morio also asked the court to render voidable any provisions to which the players association objected contained within the individually negotiated contracts entered after the board had certified the players association.

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