Arena Football League and Arena Football One LLC v. Bishop
42 FLW D1298
Claimant was injured while trying out for a position with the Arena Football League Orlando Predators. The parties agreed that the claimant's claim was dependent on the contract that the claimant had with the football team. The parties stipulated that whether the claimant was an employee at the time of this accident depends on his contract with the football team. Court determined that when reviewing contracts to determine coverage, review is de novo.
The contract that the claimant signed was to be executed by three parties - the claimant, a team representative, and a league representative. The claimant and the team representative had signed the contract but the leage had not. The question in this case was whether there was a contract or wasn't there? The claimant argued that there was a contract since there was nothing contained in the agreement that says that all parties were required to sign. The court rejected this argument since a contract can be enforceable against the non-signator simply because of the fact that the contract does not expressly provide that signatures are required.
The claimant also argued that there was a provision in the agreement that the league could unilaterally cancel the contract without an agreement between the claimant and the team. However, the contract also provided that absent this approval, it would become effective in 7 days automatically. There was no notice from the leage that the contract was disapproved. However, this did not mean that a contract was automatically approved or that a binding agreement was formed.
Court determined that there was no contract between the claimant and the team contrary to the decision by the JCC. Accordingly, there was no employer/employee relationship on the date of the injury.