The National Football League Players Association (NFLPA) did not improperly interfere with the rights of National Football League (NFL) retirees under the Restatement of Torts, when it exclusively negotiated with the NFL about retirement issues. The NFLPA approved a ten-year settlement agreement with the NFL concerning pension, retirement, and disability benefits without consulting retired NFL players. Under the Restatement of Torts, wrongful interference with prospective contractual relations requires that the interference was both “intentional” and “improper.” The district court ruled that the NFLPA did not improperly interfere with the retiree’s prospective contractual relations because the NFLPA had no actual desire to effectuate interference and it did not have a reasonable expectation that the retired players possessed a prospective economic advantage in the negotiation process.
See Eller v. Nat’l Football League Players Ass’n, 872 F. Supp. 2d 823 (D. Minn. 2012); Restatement (Second) of Torts, § 766B (1979).
(Development authored by Mike Fallings)