By Connor J. Whelan
In August of 2014, the Jackie Robinson West Little League team, made up entirely of African-American players from Chicago, won the Little League World Series. In February of 2015, the team was stripped of their title due to residency violations, as an investigation revealed that some members of the team did not live inside the boundaries as set forth in league guidelines. Following the Little League World Series in September of 2014, Chris Jones, the vice president of another local league, alerted Little League of the infractions. Prior to the qualifying tournaments, Jackie Robinson West Little League submitted their binder of information including birth certificates and addresses to the Little League District 4 office, which was then forwarded to the Little League Central Regional Office. The addresses of the players were correct, yet some fell outside of the residency boundaries. Head coach Darold Butler, team president Annie Haley, and district administrator Michael Kelley all signed a document confirming that the binder of information, known as a tournament affidavit, was accurate.
The parents of Jackie Robinson West Little League claim that the regional tournament director for Little League, as well as other Little League officials, notified Bill Haley of residency issues, but that the notifications went ignored. Haley was found to have retroactively changed the residency map, thus making all players eligible. In December of 2014, Coach Butler was suspended and Kelley was removed from his position. In February of 2015, ESPN First Take aired a segment featuring Stephen A. Smith’s scathing analysis of the coaches, administrators, and parents. The roughly 7-minute segment would be used as evidence in the parent’s lawsuit against ESPN and Stephen A. Smith.
A year later, in February of 2016, the parents of Jackie Robinson West Little League on behalf of themselves and their children filed a 22-count complaint against Little League, Jackie Robinson West Little League Inc., Bill and Annie Haley, ESPN, and Stephen A. Smith. The parents of the players claimed that Little League knew or should have known that the players were in breach of Little League rules and did not enforce them, impacting negatively both players and parents. Additionally, the parents claimed Stephen A. Smith falsely accused the parents of participating in the cheating scandal. Little League, ESPN/Stephen A. Smith, Jackie Robinson West Little League Inc., and the Haleys all filed motions to dismiss. The trial court dismissed all counts related to the parents and severed the case from the children’s case, which now moves to a different trial. The appeals court examined and analyzed each claim set forth.
Reinstatement of Championship
In the complaint, the parents argued that the reinstatement of the Little League World Series Championship would be the one thing that would make them all whole again. Little League notes that reinstatement is a possible remedy, but that the parents failed to prove their standing for reinstatement. The court ruled that the burden of proof is on Little League to show that the parents lack standing for reinstatement. The plaintiffs argue that Little League and the team agreed to mutual rules they would both follow. Little League failed to follow its own rules, leading to breach of implied contract. This in turn led players and parents to forfeit dues paid, time, and ultimately the 2014 Little League World Series title. The appeals court agreed with this argument, stating that the issues should be redressed by reinstating the title. The parents allege promissory estoppel and argue that the players followed Little League regulations to their own detriment. Little League looked to dismiss, stating that only Jackie Robinson West Inc. could look to reinstate the title, but the appeals court dismissed this argument due to associational standing.
Defamation
The parents claimed the trial court erred in dismissing their claims as it related to Stephen A. Smith’s First Take broadcast. The parents alleged per quod defamation, while Butler alleged per se defamation, claiming that Stephen A. Smith suggested he committed the crime of fraud. The trial court ruled Smith’s comments as nonactionable and that his opinion was protected speech under the First Amendment. Additionally, the court argued that Smith’s comments did not sufficiently link Butler to committing an actual crime. Cheating in sports, while bad practice, is usually not a criminal act. In a defamation lawsuit, specific damages need to be highlighted by the plaintiff, which by and large were not provided by the Jackie Robinson West parents. The court concurs that Smith’s on-air comments were both loose and careless, but the parents did not establish how those comments led to defamation.
Intentional Infliction of Emotional Distress
The parents alleged intentional infliction of emotional distress against Little League, ESPN, and Stephen A. Smith. The court noted that this claim has a high standard, and conduct must be extreme and outrageous to constitute intentional infliction of emotional distress. As it relates to Little League, the parents claim that Haley’s concealment of eligibility, and then the stripping of the title before the parents could challenge the ruling, was extreme and outrageous. The court disagreed with this, as Jackie Robinson West Little League Inc.’s power over the parents is marginal, and regardless, the conduct was neither extreme nor outrageous. The appeals court also affirmed the trial court on this count as it relates to Stephen A. Smith since he never mentioned any of the parents’ names, other than Butler who was the head coach.
Negligent Infliction of Emotional Distress
For negligent infliction of emotional distress to be established, the main requirements for negligence must be met. As it relates to this count, the parents did not allege any sort of physical injury making this claim baseless. The appeals court ultimately dismissed this claim.
False Light Invasion of Privacy
False light invasion of privacy protects individuals from being harassed on the basis of false publicity. The parent’s argument against Little League is that Little League painted them in a false light with the press release announcing the stripping of the title. The court dismissed this claim saying that nothing in the press release was false. As it relates to this claim against Smith, the court ruled once again that his speech was protected by the First Amendment.
Civil Conspiracy
The parents alleged that Little League, Jackie Robinson West Inc., and the Haleys all conspired to conceal the eligibility of the players. The court poked a number of holes in this count and ultimately dismissed it, citing lack of evidence that the parties named actually conspired.
The appellate court reversed the trail court’s decisions on the breach of implied contract and promissory estoppel, leaving a possible remedy in the form of a reinstatement of the championship. Since the court cases between the parents and children have now been split, this will be decided in the trial court for the children’s case 18 L 00178.
Connor J. Whelan is a doctoral student of Sport Management at Troy University. He is currently the Assistant Athletic Director for Marketing and External Engagement at the University of Louisiana at Lafayette.
