Justia Entertainment & Sports Law Opinion Summaries

A Texas law, Senate Bill 12, regulates sexually oriented performances on public property and in the presence of minors. The law defines such performances as visual acts featuring nudity or sexual conduct that appeal to the prurient interest in sex. Several organizations and individuals involved in drag performances brought a pre-enforcement challenge, arguing that the law facially violates the First Amendment. The plaintiffs included groups that host pride festivals and drag events, as well as individual performers and entertainment companies.The United States District Court for the Southern District of Texas held a two-day bench trial. After reviewing the evidence, the district court found that the law was a facially unconstitutional restriction on speech and issued a permanent injunction preventing the Attorney General of Texas, certain district attorneys, counties, and a city from enforcing the law.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether each plaintiff had standing to seek injunctive relief against each defendant. The Fifth Circuit found that most plaintiffs did not intend to engage in conduct arguably proscribed by the law and therefore lacked standing. Only one plaintiff, 360 Queen Entertainment, LLC, demonstrated standing to seek an injunction against the Attorney General, as its performances arguably included conduct regulated by the statute and minors were sometimes present.The Fifth Circuit vacated the district court’s injunction and remanded the case. The court instructed the district court to dismiss claims against all defendants except the Attorney General and to reconsider the facial challenge to Section One of the law under the framework set forth in Moody v. NetChoice, LLC. The court emphasized that a facial challenge requires showing that a substantial number of the law’s applications are unconstitutional in relation to its legitimate sweep. View "Woodlands Pride v. Paxton" on Justia Law

A former professional football player, who played in the National Football League for 15 seasons, filed a workers’ compensation claim in California alleging cumulative injuries sustained throughout his career. He began his career with a California-based team, signing his initial contract in California, but spent the majority of his career with out-of-state teams, including the Atlanta Falcons, for whom he played his final seasons. During his employment with the Falcons, he played only a small number of games in California and spent the majority of his duty days outside the state.A workers’ compensation judge determined that both the player and the Falcons were exempt from California workers’ compensation law under specific statutory provisions, as the Falcons provided workers’ compensation coverage under another state’s laws and the player did not meet the statutory thresholds for California coverage. The Workers’ Compensation Appeals Board (WCAB), upon reconsideration, disagreed, finding that it had jurisdiction over the claim because the player had signed a contract in California during his career, and it rescinded the judge’s decision.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that the Falcons are exempt from California workers’ compensation law under Labor Code sections 3600.5(c) and (d), because the player did not spend enough of his career working for California-based teams or in California, and he played more than seven seasons for non-California teams. The court annulled the WCAB’s decision and remanded the matter for further proceedings consistent with its opinion, holding that the statutory exemptions for professional athletes applied and precluded the player’s claim against the Falcons under California law. The court awarded costs in connection with the writ proceeding to the Falcons. View "Atlanta Falcons v. Workers' Comp. Appeals Bd." on Justia Law

Karen L. Willis, operating as Harlem West Entertainment and married to Victor Willis, the original lead singer of the Village People, alleged that the Walt Disney Company and related entities engaged in unfair competition and fraud. The dispute arose after Disney hired the reconstituted Village People, led by Victor Willis, for performances at Walt Disney World in 2018. Following these events, Willis claimed Disney instituted a secret ban on booking the Village People for future concerts and made misleading statements to the band’s agents about potential future engagements. Willis asserted that Disney’s actions, including evasive communications and refusal to consider booking proposals, constituted unlawful, unfair, and fraudulent business practices.The Superior Court of San Diego County reviewed Disney’s special motion to strike the complaint under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16). The trial court denied Disney’s motion, finding that Disney failed to meet its initial burden of showing that the conduct alleged in Willis’s complaint was protected activity under the anti-SLAPP statute’s catchall provision. The court concluded that, although the conduct implicated a public issue, it did not further or participate in a public conversation about that issue. As a result, the trial court did not address Disney’s evidentiary objections or whether Willis’s claims had minimal merit.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and reversed the trial court’s order. The appellate court held that Disney’s selection of musical acts for public concerts and its related communications with the Village People’s agents were protected conduct under the anti-SLAPP statute’s catchall provision. The court remanded the case to the trial court to determine whether Willis’s claims have minimal merit, as required by the second prong of the anti-SLAPP analysis. View "Willis v. The Walt Disney Company" on Justia Law

A transgender woman sought to compete in the women’s division of powerlifting competitions organized by a national governing body. After registering and applying for a therapeutic use exemption to take a medication as part of her gender-affirming care, she was informed that the organization’s policy categorically barred transgender women from competing in the women’s division. The organization justified its policy by asserting that transgender women have an unfair competitive advantage due to “male physiology.” The woman’s competition card was revoked, and she was denied participation.The case was first heard in the Minnesota District Court, which granted partial summary judgment in favor of the plaintiff on her claims of sexual orientation discrimination in both public accommodations and business, as well as sex discrimination in business, under the Minnesota Human Rights Act (MHRA). The district court found the organization’s policy facially discriminatory and not justified by a legitimate business purpose. However, it denied summary judgment on the claim of sex discrimination in public accommodations, citing a statutory exemption for athletic events. The court also issued injunctive relief, ordering the organization to cease discriminatory practices and revise its policy.On appeal, the Minnesota Court of Appeals reversed the district court’s grant of partial summary judgment and injunctive relief, finding genuine issues of material fact regarding the organization’s motivation and the applicability of the legitimate business purpose defense.The Minnesota Supreme Court held that the organization’s policy was facially discriminatory and constituted direct evidence of discrimination based on sexual orientation under the MHRA. The court reinstated summary judgment for the plaintiff on the public accommodations claim, as no statutory defense was asserted. However, it found a genuine dispute of material fact regarding the legitimate business purpose defense for the business discrimination claim, affirming the appellate court’s reversal on that issue. The case was remanded for further proceedings. View "Cooper vs. USA Powerlifting" on Justia Law

Wayne Gandy, a professional football player, spent 15 years in the NFL, beginning with the Los Angeles Rams in 1994, then the St. Louis Rams, followed by the Pittsburgh Steelers, New Orleans Saints, and finally the Atlanta Falcons until his retirement in 2009. Gandy signed his initial contract in California with the LA Rams, which also covered his time with the STL Rams. Throughout his career, he played a limited number of games and practiced occasionally in California, but the majority of his employment and games were outside the state.After retiring, Gandy filed a workers’ compensation claim in California in 2015, alleging cumulative injuries from his NFL career. The claim named several teams as employers. The Workers’ Compensation Judge (WCJ) found that the Falcons provided workers’ compensation coverage under Georgia law, which also covered Gandy’s work in California, and determined both Gandy and the Falcons were exempt from California workers’ compensation law under Labor Code section 3600.5. The WCJ did not address the liability of other teams. Gandy petitioned for reconsideration, and the Workers’ Compensation Appeals Board (WCAB) rescinded the WCJ’s decision, asserting jurisdiction over Gandy’s claim based on his initial California contract and disregarding the choice of law and forum selection clauses.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that the Falcons are exempt from liability under California workers’ compensation law pursuant to Labor Code sections 3600.5(c) and (d), as Gandy did not meet the statutory requirements for coverage: he worked only one season for a California-based team and spent less than 20 percent of his career in California. The WCAB’s decision was annulled, and the matter was remanded for further proceedings consistent with this opinion. View "Atlanta Falcons v. Workers' Compensation Appeals Bd." on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law

A Texas statute, Senate Bill 315, prohibits individuals under 21 from working at sexually oriented businesses (SOBs) to prevent sex trafficking and sexual exploitation. Plaintiffs, including the Texas Entertainment Association and several adult cabarets and bookstores, challenged the constitutionality of S.B. 315 under the First Amendment, suing the Texas Attorney General and the Executive Director of the Texas Workforce Commission.The United States District Court for the Western District of Texas held a bench trial and upheld the statute as constitutional. The court found that Texas enacted S.B. 315 with the reasonable belief that it would curb sex trafficking and that the law was sufficiently tailored to that end. The court applied intermediate scrutiny, concluding that the statute furthered the state's interest in reducing sex trafficking and did not restrict substantially more speech than necessary.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that intermediate scrutiny was appropriate. The court found that S.B. 315 was designed to serve a substantial governmental interest by providing evidence linking SOBs to sex trafficking and sex crimes. The court also determined that the statute allowed for reasonable alternative avenues of communication, as it did not significantly restrict the expressive conduct of SOBs or their employees. The court concluded that S.B. 315 was not overbroad, as the plaintiffs failed to demonstrate that the statute prohibited or chilled a substantial amount of protected speech. Thus, the Fifth Circuit held that S.B. 315 is constitutional under the First Amendment. View "Ass’n of Club Executives v. Paxton" on Justia Law

Two defendants, Hernán Lopez, a top executive at Twenty-First Century Fox, and Full Play Group, S.A., a South American sports marketing company, were convicted of conspiracy to commit honest services wire fraud related to a FIFA corruption scandal. They were involved in bribery schemes to secure media rights for various soccer tournaments, including the Copa Libertadores, Copa América, and World Cup qualifiers. The government presented evidence that Full Play bribed officials from several South American soccer federations, while Lopez was implicated in a scheme involving T&T Sports Marketing, a joint venture of Fox and Torneos y Competencias, to secure undervalued media rights contracts through bribery.The United States District Court for the Eastern District of New York initially denied pre-trial motions to dismiss the indictment but later granted post-trial motions for acquittal under Rule 29(c). The district court reasoned that, following the Supreme Court’s decisions in Percoco v. United States and Ciminelli v. United States, the conduct did not fall within the scope of honest services wire fraud under 18 U.S.C. § 1346, and the evidence was insufficient to sustain the convictions.The United States Court of Appeals for the Second Circuit reviewed the case and held that the district court erred in its conclusion. The appellate court determined that the conduct of Lopez and Full Play did fall within the ambit of § 1346, as it involved bribery, which is a core application of the honest services fraud statute. The court noted that the fiduciary duties breached by the bribed officials were established by their relationships with FIFA and CONMEBOL, and these duties were informed by the organizations' codes of ethics. Consequently, the Second Circuit vacated the district court’s judgments of acquittal and remanded the case for further proceedings consistent with its opinion. View "United States v. Lopez" on Justia Law

Sydney Walton, a fourteen-year-old, suffered a concussion and other head injuries during an indoor soccer practice at a Baltimore County-owned facility. The plaintiffs, her family, alleged that the defendants, including Premier Soccer Club, Inc., its coach, and several Baltimore County employees, were negligent in violating a Maryland statute designed to ensure that parents, players, and coaches in youth sports are informed about the risks of concussions and best practices for preventing and handling them.The Circuit Court for Baltimore County granted summary judgment in favor of the defendants on the negligence claim based on the statutory violation. The court found that the plaintiffs failed to provide evidence that the alleged statutory violations proximately caused Sydney's injuries. The plaintiffs appealed, but the Appellate Court of Maryland affirmed the circuit court's decision, agreeing that the plaintiffs did not establish the necessary causation-in-fact.The Supreme Court of Maryland reviewed the case and affirmed the judgment of the Appellate Court. The court held that to establish a prima facie case of negligence based on a statutory violation, the plaintiff must show that the defendant violated a statute designed to protect a specific class of persons that includes the plaintiff and that the violation proximately caused the plaintiff's injury. The court emphasized that proximate cause requires evidence of both causation-in-fact and legal causation. The plaintiffs failed to provide sufficient evidence to establish that the statutory violations were the cause-in-fact of Sydney's injuries, and thus, the summary judgment in favor of the defendants was upheld. View "Walton v. Premier Soccer Club" on Justia Law

David Katleski, an experienced golfer, was struck by an errant golf ball while participating in a tournament at Cazenovia Golf Club. The accident occurred during a "shotgun start" tournament, where players tee off simultaneously from different holes. Katleski was hit while searching for a ball on the seventh fairway by a ball hit from the third hole. He sued the golf club, alleging negligent design and operation of the course, particularly the placement of tee box A on the third hole.The Supreme Court denied the club's motion for summary judgment, finding a triable issue of fact regarding whether the course's design unreasonably enhanced the risk. The Appellate Division reversed, granting summary judgment to the club, emphasizing Katleski's experience and awareness of the course layout. The court found no evidence that the course design exposed Katleski to risks beyond those inherent in golf. Katleski appealed to the Court of Appeals.The New York Court of Appeals affirmed the Appellate Division's decision, holding that the primary assumption of risk doctrine precluded Katleski's negligence claim. The court found that being struck by a mishit golf ball is an inherent risk of the sport, and there was no evidence that the course design unreasonably enhanced this risk.Mary Galante was injured in a separate incident at Elma Meadows Golf Course when she collided with a car while driving a golf cart in the parking lot. The Appellate Division denied her motion to strike the County's primary assumption of risk defense and granted summary judgment to the County. The Court of Appeals reversed, holding that the primary assumption of risk doctrine did not apply as Galante was not participating in a protected athletic or recreational activity at the time of her injury. The case was remitted to the Appellate Division for further consideration. View "Katleski v Cazenovia Golf Club, Inc." on Justia Law