By Steven Stamps
The United States District Court for the Southern District of California has upheld an arbitrator’s decision that a NFL player could pursue a workers’ compensation claim in California but that the claim must proceed under Tennessee law. The court ruled against Bruce Matthews, the player, on the basis that the arbitrator did not manifestly disregard the law and the award was not contrary to public policy.
Bruce Matthews played in the NFL for nearly 20 years. His Hall of Fame career spanned from 1983 until 2002. During his career, Matthews played for the Houston Oilers/Tennessee Titans. As an NFL player, Matthews was bound by a collective bargaining agreement (CBA) between the NFL Players’ Association and the NFL owners. The CBA provides all disputes arising out of the collective bargaining agreement are adjudicated through final and binding arbitration. Matthew’s contract with the Titans provided that “all issues of law, issues of fact, and matters related to workers compensation benefits shall be exclusively determined by and exclusively decided in accordance with internal laws of the State of Tennessee without resort to choice of law rules.”
Matthews filed a workers’ compensation claim in California approximately five years after his playing career ended. The Titans filed a grievance against Matthews for improperly filing a claim in violation of his contract, which required workers’ compensation benefits to be handled under Tennessee law. As required under the CBA, the grievance was sent to arbitration. The arbitrator found that Matthews had violated his player contract by filing a claim for workers’ compensation in California and requesting that the claim be processed under California law. The arbitration award forced Matthews to proceed with his workers’ compensation claim under Tennessee law. Matthews then filed suit, asking the court to vacate the arbitration award.
The court stated that there were two bases for possibly vacating the arbitration award: manifest disregard of the law by the arbitrator or an award against public policy. For a court to vacate an arbitration award on the basis of disregard of the law, an erroneous interpretation is not enough. The arbitrator must understand the law and still disregard it. To vacate an arbitration award for a violation of public policy, there must be an explicit, well-defined, and dominant public policy that specifically militates against the arbitrator’s award.
In the case at hand, the court found that there was no clear evidence in the record that shows that the arbitrator recognized the applicable law and then ignored it. The court then analyzed the arbitrator’s decision against California law, the Full Faith and Credit Clause of the Constitution, and federal law to determine whether it was against public policy. The court decided that there was not an explicit, well-defined, and dominant public policy specifically militating against the arbitrator’s award.
As a result of these findings, the court held that it would not vacate the decision of the arbitrator. The decision required Matthews to request the California Workers’ Compensation Appeals Board to issue any award in accordance with Tennessee law or to withdraw his claim if the Board declined to do so.
Stamps is an associate at the Law Office of Ricky D. Green, PLLC in Austin, TX, where he specializes in workers’ compensation issues. He is also a frequent contributor to Sports Litigation Alert.
