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Judge overstepped authority in NFL comp case: Appeals court

Judge overstepped authority in NFL comp case: Appeals court

A judge exceeded his authority in finding that a National Football League bargaining agreement limits teams from seeking dollar-for-dollar reimbursement of workers compensation benefits they pay to injured football players, the 2nd U.S. Circuit Court of Appeals has ruled.

In National Football League Players Association v. National Football League Management Council, the NFL Players Association sought to prevent NFL teams from collecting workers comp benefits paid to players after their team contracts have ended.

The NFL Management Council represents the 32 NFL football teams in collective bargaining negotiations, while the players association is the union for athletes.

Under the NFL's collective bargaining agreement, NFL teams are required to pay injured players a full salary through the end of the season in which they're injured, as well as a limited salary in the next season if the player remains unable to work and his contract is terminated, according to court records. The agreement allows NFL teams to deduct any state workers comp benefits received by a player from his salary.

NFL teams sought a “dollar-for-dollar” offset, in which they could collect a player's comp benefits until they are fully reimbursed for any salary paid to the player while he is injured — even if his contract expires before reimbursement is completed, according to court records. However, the players association argued that teams should be allowed only a “time offset” allowing collection of benefits while the player remains under contract with his team.


Arbitration and federal court rulings found that the collective bargaining agreement allows NFL teams to be reimbursed only while a player's contract is in effect, court records show. After teams continued seeking the dollar-for-dollar reimbursement under state laws, the U.S. District Court in White Plains, N.Y., found in 2012 that the collective bargaining agreement pre-empts state laws.

However, the appeals court vacated that 2012 ruling last week, finding that the district court did not have authority to decide whether the bargaining agreement trumped state law. Specifically, it said district courts are limited by the Federal Arbitration Act in their ability to judge arbitration awards.

“Here, when the district court held that (the bargaining agreement) pre-empted contrary state law, it in effect expanded the terms of the arbitration award,” a three-judge panel of the appeals court said in an order on Friday.

The appeals court said that the players association can file a separate lawsuit to argue whether the bargaining agreement trumps state laws that would allow dollar-for-dollar reimbursement.

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