Justia Entertainment & Sports Law Opinion Summaries

The plaintiffs, a group of professional models, alleged that the defendant, an adult entertainment nightclub, used their images in social media posts without consent to promote the club between August 2013 and November 2015. The plaintiffs filed a lawsuit in 2021 in the United States District Court for the District of Massachusetts, claiming defamation and related torts. This filing was outside the three-year statute of limitations specified by Massachusetts law. To avoid dismissal, the plaintiffs argued for the application of the "discovery rule," which would delay the start of the limitations period until they knew or reasonably should have known about the harm.The United States District Court for the District of Massachusetts noted that the application of the discovery rule to social media posts was a novel issue in Massachusetts law. The court certified a question to the Supreme Judicial Court of Massachusetts, asking under what circumstances material posted on social media platforms could be considered "inherently unknowable" for the purposes of applying the discovery rule in defamation and related tort claims.The Supreme Judicial Court of Massachusetts held that claims arising from social media posts accrue when a plaintiff knows or reasonably should know they have been harmed by the publication. The court emphasized that the vastness of social media and the variability in access and searchability require a fact-specific inquiry. The court concluded that whether the plaintiffs knew or should have known about the harm must often be determined by the finder of fact. However, if the social media material is widely distributed and readily accessible and searchable, a judge may determine as a matter of law that the discovery rule does not apply. View "Davalos v. Bay Watch, Inc." on Justia Law

Henry Searcy, Jr. sought certification as an agent under the NFLPA’s 2012 Regulations Governing Contract Advisors but failed the required exam twice. After an arbitrator sided with the NFLPA, Searcy sued the NFLPA, its Executive Director, Prometric LLC, and Prometric’s Vice President and General Counsel. He alleged breach of contract, negligence, negligent misrepresentation, intentional infliction of emotional distress, and tortious interference with a contractual relationship, and sought vacatur of the arbitration award under the FAA.The United States District Court for the District of Columbia dismissed the claims against Prometric Defendants for lack of subject matter jurisdiction and against the NFLPA Defendants for failure to state a claim. On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of claims against Prometric Defendants and instructed the District Court to reconsider its dismissal of claims against the NFLPA Defendants, specifically examining whether Section 301 of the LMRA preempted Searcy’s state law claims.Upon further review, the District Court concluded it had jurisdiction and dismissed the claims under Rule 12(b)(6). Searcy appealed again. The United States Court of Appeals for the District of Columbia Circuit held that the District Court erred in finding subject matter jurisdiction over the claims against the NFLPA Defendants. The court determined that Section 301 of the LMRA does not completely preempt Searcy’s state law claims, as these claims do not require interpretation of the NFL-NFLPA Collective Bargaining Agreement. Consequently, the appellate court affirmed the dismissal on different grounds and remanded the case with instructions to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1). View "Searcy v. Smith" on Justia Law

The case involves a constitutional challenge to the Horseracing Integrity and Safety Act of 2020 (“HISA”). The Act empowers a private corporation, the Horseracing Integrity and Safety Authority (“Authority”), to create and enforce nationwide rules for thoroughbred horseracing. The plaintiffs, a group of horsemen's associations and other stakeholders in the horseracing industry, argued that the Act violated the private nondelegation doctrine, the Due Process Clause, the Appointments Clause, and the Tenth Amendment.The district court had previously held that an amendment to the Act, which gave the Federal Trade Commission (FTC) the power to abrogate, add to, or modify the Authority’s rules, cured the Act’s constitutional deficiencies. The district court also rejected claims that the Act violated the Constitution’s Appointments Clause and the Tenth Amendment.On appeal, the United States Court of Appeals for the Fifth Circuit agreed with the district court that the FTC’s new rulemaking oversight meant the agency was no longer bound by the Authority’s policy choices, thereby resolving the nondelegation problem with the Authority’s rulemaking power. The court also agreed that the Act did not violate the Due Process Clause or the Appointments Clause.However, the court disagreed with the district court regarding the Act’s enforcement provisions. The court held that the Act’s enforcement provisions, which empowered the Authority to investigate, issue subpoenas, conduct searches, levy fines, and seek injunctions without the FTC’s approval, violated the private nondelegation doctrine. The court declared these enforcement provisions facially unconstitutional. The court also affirmed the district court’s finding that one of the plaintiffs lacked standing to bring a Tenth Amendment challenge. View "National Horsemen’s Benevolent and Protective Association v. Black" on Justia Law

This case involves a dispute between the owners of El Gran Combo, one of the most popular Puerto Rican bands in history, and the band's former lead vocalist, Carlos Aponte-Cruz. The dispute centers on the interpretation of the Digital Performance Right in Sound Recordings Act of 1995, which entitles the "recording artist or artists featured on [a] sound recording" to a 45% share of certain royalties that the recording generated. Aponte-Cruz argues that he is the "artist . . . featured" on certain El Gran Combo sound recordings for which he was the lead vocalist and is therefore entitled to his portion of the 45% share of the statutory royalties for those recordings. The owners of El Gran Combo, on the other hand, contend that the band as an independent entity distinct from any of its individual members is the "artist . . . featured" on those recordings.The United States District Court for the District of Puerto Rico ruled in favor of the owners of El Gran Combo, finding that the band, as a distinct legal entity, was the group most prominently featured on the sound recordings and thus entitled to collect the royalties as the featured artist. The court also ruled that Rafael Ithier, as the sole owner of El Gran Combo, was entitled to collect the featured artist royalties due to the corporation.On appeal, the United States Court of Appeals for the First Circuit reversed the District Court's ruling. The appellate court concluded that even though the covers for the El Gran Combo albums that contain the disputed recordings refer only to the band itself and not to any of its individual members, Aponte-Cruz, as a "recording artist . . . featured" on the recordings in dispute, is entitled to his portion of the 45% share of the statutory royalties for those recordings. The court found that neither EGC Corp. nor Ithier is entitled to the 45% royalty share in the recordings at issue. View "Ithier v. Aponte Cruz" on Justia Law

The case revolves around the defendant, Larry Jean Hart, who was charged with capital murder while committing or attempting to commit the felony offense of burglary. Hart drove an acquaintance and three other individuals to an apartment complex where they robbed and shot the complainant, Michael Gardner. Hart claimed he remained in the car during the incident and was unaware of the group's intentions. The State argued that Hart knew about the planned crime and should have anticipated the outcome.The trial court admitted rap videos during the guilt phase of the trial to demonstrate Hart's character and sophistication. Hart objected, arguing that the videos' prejudicial effect outweighed their probative value. The trial court overruled Hart's objections, stating that Hart's testimony opened the door to character witness evidence. The jury found Hart guilty and sentenced him to life without parole.On appeal, Hart argued that the trial court erred in admitting the rap videos, among other things. The appellate court upheld the trial court's ruling, stating that the rap videos were relevant to Hart's ability to comprehend and form intent regarding the planned crime. The court also conducted a balancing test under Rule 403 and concluded that the trial court's ruling did not constitute a clear abuse of discretion.The Court of Criminal Appeals of Texas disagreed with the lower courts. It found that the rap videos' probative value was outweighed by their potential for prejudice and confusion. The court reversed the judgment of the appellate court and remanded the case to the trial court for further proceedings. View "Hart v. State of Texas" on Justia Law

The case involves Zion Williamson, a former Duke University basketball player, and Prime Sports Marketing, LLC, and its president, Gina Ford. Williamson signed a contract with Prime Sports for marketing representation after his last game at Duke but before being drafted into the NBA. However, Williamson terminated the contract shortly after and signed with a competitor agency, Creative Artists Agency (CAA). Prime Sports argued that Williamson was not a "student-athlete" when he signed the contract, and therefore, he could not benefit from the protections of the North Carolina Uniform Athlete Agents Act, which governs contracts between student-athletes and their agents.The United States District Court for the Middle District of North Carolina rejected Prime Sports' argument and granted summary judgment to Williamson on Prime's contract and tort claims. The court ruled that Williamson was a "student-athlete" when he signed the contract with Prime Sports, and Prime's failure to comply with the Act's requirements voided the contract.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court agreed that Williamson was a "student-athlete" when he signed the contract and that Prime's failure to comply with the Act's requirements voided the contract. The court also affirmed the district court's grant of summary judgment on Prime's contract and tort claims. View "Williamson v. Prime Sports Marketing, LLC" on Justia Law

A car accident occurred during Race Wars 2, an amateur drag racing event organized by Flyin’ Diesel Performance & Offroad, L.L.C. The accident resulted in injuries and deaths among spectators. The injured parties and representatives of the deceased sued Flyin’ Diesel, who turned to their insurer, Kinsale Insurance Company, for legal defense. The dispute centered on whether Kinsale owed a duty to defend Flyin’ Diesel under their commercial general liability insurance policy.The case was first heard in the United States District Court for the Western District of Texas. The district court found the insurance policy ambiguous and ruled that Kinsale owed Flyin’ Diesel a duty to defend. Flyin’ Diesel was granted partial summary judgment, and Kinsale's motion was denied. Kinsale appealed this decision.The case was then reviewed by the United States Court of Appeals for the Fifth Circuit. The appellate court disagreed with the district court's finding of ambiguity in the insurance policy. The court determined that the policy unambiguously excluded the claims made by the injured parties from coverage. Therefore, the court concluded that Kinsale was not obligated to defend Flyin’ Diesel in the lawsuit. The court reversed the district court's partial summary judgment for Flyin’ Diesel and remanded the case with instructions to grant summary judgment to Kinsale. View "Kinsale Ins v. Flyin' Diesel Performance" on Justia Law

Marvin Jackson attended a World Wrestling Entertainment (WWE) event and alleges that a pyrotechnics blast caused him to lose most of his hearing in his left ear. The tickets were purchased as a surprise gift by his nephew, Ashton Mott, on SeatGeek.com. All ticket purchases required agreement to various terms and conditions, including an arbitration agreement, and stated that entry to the event would constitute acceptance of these terms. Jackson sued WWE in Texas state court for negligence, but WWE moved the case to federal court and requested arbitration per the ticket agreement. The district court granted WWE’s motion, stating that Mott acted as Jackson's agent and that Jackson was therefore bound by the terms of the ticket, including the arbitration agreement.Jackson appealed the decision, arguing that Mott did not have the authority to act on his behalf and therefore the arbitration agreement should not be enforceable against him. The United States Court of Appeals for the Fifth Circuit disagreed with Jackson's argument. The court held that although Mott purchased the tickets without Jackson's knowledge or control, he acted as Jackson’s agent when he presented the ticket on Jackson's behalf for admittance to the event. The ticket's terms and conditions were clear that use of the ticket would constitute acceptance of the arbitration agreement. Therefore, the court affirmed the district court's decision to compel arbitration, as the arbitration agreement is enforceable against Jackson. View "Jackson v. World Wrestling" on Justia Law

In this case, a minor identified as M.U., through her parents, filed a complaint against Team Illinois Hockey Club, Inc. and the Amateur Hockey Association of Illinois, Inc., alleging that they violated Section 5-102(A) of the Illinois Human Rights Act by discriminating against her due to her disability. M.U. claimed that Team Illinois excluded her from participating in its activities at Seven Bridges Ice Arena, a public accommodation, due to her mental health conditions, thereby denying her full and equal enjoyment of the facilities and services.The defendants filed a motion to dismiss the complaint, arguing that M.U.'s allegations pertained to her exclusion from the team and its activities, not a place of public accommodation. The circuit court agreed and dismissed the complaint. The appellate court, however, reversed this decision, stating that Team Illinois, by its lease and operation of Seven Bridges, could not deny M.U., based on her disability, the privilege of participation in athletic events held at places of public accommodation.The Supreme Court of the State of Illinois affirmed the appellate court's judgment. It held that the Act did not delineate between “portions” of a place of public accommodation subject to its provisions. The court noted that, while Team Illinois itself might not be a place of public accommodation, it operated within one and was thus subject to the Act. The court concluded that M.U.'s allegations were sufficient to state a cause of action under Section 5-102(A) of the Act. The case was remanded to the circuit court for further proceedings. View "M.U. v. Team Illinois Hockey Club, Inc." on Justia Law

The Supreme Court of Alabama has reversed a lower court's decision in a case involving claims of defamation, invasion of privacy, and violation of the Alabama Right of Publicity Act. The lawsuit was filed by Jennifer South, individually and as administratrix of the estate of her deceased husband, Jules Pierre Gillette, against Regional Prime Television and Tommy Dwayne Hubbard. The case arose from an episode of a show titled 'Ghostly Encounters' that was filmed in a former school building where South and Gillette had lived. The episode included allegations that Gillette had a drinking problem, was paranoid, abused little boys, physically abused South, and locked her in a closet in their home. The Supreme Court found that South did not present substantial evidence to support her defamation claim and that the estate failed to prove that the use of Gillette's indicia of identity in the episode was "for the purposes of trade". The court rendered a judgment in favor of Hubbard and Regional Prime on the estate's right-of-publicity claim and South's defamation claim, and remanded the case for a new trial as to South's invasion-of-privacy and tort-of-outrage claims. View "Regional Prime Television v. South" on Justia Law