By Steven Stamps
The United States District Court for the Northern District of Illinois has upheld the decision of an arbitrator that members of the Chicago Bears could not pursue workers’ compensation claims in California and must do so in Illinois. The Court held that the players were unable to establish any basis for concluding that the negotiated agreements between the parties must conform to California public policy.
In 2009 and 2010, three Chicago Bears football players, Michael Haynes, Joe Odom, and Cameron Worrell, filed claims for workers’ compensation benefits with the California Workers’ Compensation Appeals Board. The Bears filed grievances with the players, arguing that they violated their contracts by pursuing their claims in California rather than Illinois. As required by the collective bargaining agreement between the NFL Players Association and the NFL, the matter proceeded to arbitration.
The grievances were heard by an arbitrator, Rosemary Townley, and were upheld. The arbitrator concluded that the choice of law and choice of forum provisions in the players’ contracts expressed the parties’ intent that all workers’ compensation claims be brought before the Illinois Industrial Commission and be adjudicated pursuant to Illinois law. The arbitrator cited an arbitration decision in Tennessee Titans v. Bruce Matthews which found that the choice of law provisions in the NFL player’s contract prohibited the player from pursuing workers’ compensation claims under California law. The arbitrator further concluded that the players breached the forum selection clause of their contracts by filing workers’ compensation claims in California. Under her authority under the collective bargaining agreement, the arbitrator ordered the players to cease and desist from pursuing their workers’ compensation claims in California.
The Bears sought judicial review in the US District Court to confirm and enforce the decision of the arbitrator. The players argued that the provisions of their contracts were void and unenforceable under California law, federal labor law, and the Full Faith and Credit Clause of the Constitution. The Bears argued that there is a strong presumption in favor of enforcing arbitration awards and that none of the players’ arguments overcome the presumption. United States District Judge Elaine Bucklo found herself asking why does this case even concern the public policy of California as there was no dispute that the contracts were formed under Illinois law, the Bears are located in Illinois, the players executed and substantially performed in Illinois, and the parties negotiated for exclusive Illinois choice of law and choice of forum provisions. Judge Bucklo held that the players did not establish any basis for concluding that the contracts must conform to the public policy of California and could not be vacated as contrary to that public policy. The Court further found that the contracts were not contrary to federal labor laws as they did not purport to supplant state law. The provisions of the contracts expressly conform to Illinois state law. Finally, the Court held that the enforcement of the contracts’ Illinois law and forum restrictions did not violate the Constitution. Judge Bucklo granted the Bears’ motion to enforce the award of the arbitrator and denied the players’ motion to vacate the award and declare the law and forum restrictions of their contracts void and unenforceable.
Stamps is a contributing writer to Hackney Publications and an attorney for the Law Office of Ricky D. Green, a firm that specializes in workers’ compensation issues.
