Brown v. National Football League
Orlando Brown, a former NFL player, and his wife Mira Brown, sued the National Football League (NFL) for personal injuries. Brown's career ended after an NFL referee negligently threw a weighted penalty flag, striking him in the eye. The case was removed from New York state court to federal court. The NFL moved to dismiss and compel arbitration, arguing the claims were preempted by Section 301 of the LMRA and related to a Collective Bargaining Agreement (CBA). Plaintiffs cross-moved to remand, asserting their claims were independent state law torts. The Court denied the NFL's motion, finding the duties alleged were general state law duties, not solely derived from the CBA. The Court granted Plaintiffs' motion to remand the case to state court.