Williams v. National Football League Case Brief Summary | Law Case Explained

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Williams v. National Football League, 582 F.3d 863 (2009)

Preemption is the idea that certain federal laws take precedence over state laws on similar or the same subject matter. In Williams versus National Football League, the Eighth Circuit sorted through state statutory and common-law claims that were possibly preempted by a federal labor law.

National Football League, or NFL, players were subject to a collective -bargaining agreement made by their union and the NFL Management Council, which bargained for the teams. The agreement included a policy on anabolic steroids and related substances banning players from using blocking or masking agents like diuretics or water pills.

Players were strictly liable for substances found in their bodies, even if they unknowingly took a prohibited substance. Players who tested positive for prohibited substances were subject to discipline and suspension from upcoming games. Players could appeal disciplinary actions to an arbitrator.

Five players tested positive for a diuretic and masking agent found in a certain dietary supplement. The substance wasn’t listed on the supplement’s labeling. The players were suspended. Each player appealed. The appeals were consolidated. Counsel for both the players and the NFL got involved. Following an arbitration hearing, the suspensions were upheld.

The players sued the NFL in Minnesota state court alleging violations of Minnesota common law, including breach of fiduciary duty and negligence. The court issued a temporary restraining order blocking the suspensions. The NFL removed the case to federal court. Separately, the players’ union sued the NFL in federal court for breach of contract. The players filed an amended complaint in federal court and added violations of Minnesota statutory law, including the Drug and Alcohol Testing in the Workplace Act.

The parties filed cross-motions for summary judgment. The court found the players’ common-law claims were preempted by Section 301 of the federal Labor Management Relations Act. The common-law claims and the union’s breach-of-contract claim were dismissed. The court found the statutory-law claims weren’t preempted by Section 301, but the federal claims had been dismissed, and the court declined supplemental jurisdiction over the Minnesota statutory-law claims. All parties appealed parts of the summary-judgment order.

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