(CN) - The 8th Circuit revived claims that owners of professional football teams violated a labor contract by colluding to set a secret cap on player salaries in 2010.
Relations between the National Football League and its players had been governed for almost two decades by a Stipulation and Settlement Agreement (SSA) that expired in 2010.
In the final year of the agreement, the 2010 season, the SSA imposed no salary cap, and many players expected a marked increase in player salaries.
This increase never occurred, however, and players began to suspect that NFL team owners were colluding to avoid bidding wars over free agents.
The parties agreed to a new collective bargaining agreement in July 2011, after an 18-week lockout that threatened the year's season.
But once the new agreement was in place, NFL Commissioner Roger Goodell and several NFL owners made public statements about an unofficial 2010 salary cap, which players interpreted as an acknowledgement of a secret salary cap in violation of the SSA.
Players then sought to reopen a 1993 case filed by now-deceased defensive end Reggie White, which was one of the legal actions that pressured the league into signing the SSA.
A federal judge in Minneapolis shot them down, but the 8th Circuit ruled Friday that the players cannot treat the SSA as a class settlement that can be revisited.
"Without the conceit that the SSA is a bargained-for result of the White litigation, the rationale for treating it as a class settlement begins to fall apart. When a defendant breaches a class settlement, he vitiates the consideration received by the plaintiffs in exchange for the forfeiture of their legal rights," Judge Roger Wollman wrote for the three-judge panel. "But when a defendant breaches an independent contract signed with members of the class, the legal rights of the class at issue in the lawsuit are not implicated. The mere fact that a class has suffered a harm, seventeen years after they were certified for purposes of unrelated litigation, does not mean that they may seek redress for that harm as a class."
Rule 60(b), which allows a court to set aside a final judgment if it was obtained by misrepresentation, may still offer the players relief, the St. Louis-based court ruled.
"Our holding should not be read as in any way expressing a view on the merits of the association's Rule 60(b) motion," Wollman wrote. "'Rule 60(b) authorizes relief in only the most exceptional of cases,' and the association bears a heavy burden in attempting to convince the District Court that the dismissal was fraudulently procured. We hold only that the association should be given the opportunity to meet this burden."