## Facts

- Central New York Basketball, Inc. owned the Syracuse Nationals, an NBA franchise.
- Richard “Dick” Barnett, Syracuse’s 1959 first-round draft pick, played for Syracuse in 1959–60 under an NBA Uniform Player Contract and in 1960–61 under the contract’s renewal option at $8,500.
- The contract included an option permitting Syracuse to renew for an additional year if no new agreement was executed; Syracuse asserted it properly exercised the option for 1961–62.
- In May 1961, Barnett and Syracuse’s president reached an oral telephone agreement that Barnett would play for Syracuse in 1961–62 for $11,500.
- In July 1961, Barnett signed an ABL player contract with Cleveland Basketball Club, Inc. (Cleveland Pipers) for September 15, 1961 to September 14, 1962 at approximately $13,000.
- Syracuse alleged the Pipers knew of Syracuse’s claimed renewal right and nonetheless induced Barnett to sign.
- Syracuse alleged Barnett’s playing services were special and not readily replaceable, making money damages inadequate.
- Syracuse sued for injunctive relief to bar Barnett from playing for the Pipers and to bar the Pipers from employing him during the 1961–62 season.

## Issues

1. Whether the NBA Uniform Player Contract, its renewal option, and the later telephone agreement created an enforceable obligation binding Barnett to play for Syracuse for the 1961–62 season.
2. If an enforceable obligation existed, whether equity could enjoin Barnett from playing for a rival club and enjoin the rival club from employing him during the contract term based on uniqueness of services and inadequacy of legal damages.

## Decision

- The court found Barnett was bound by a valid, enforceable obligation to Syracuse for the 1961–62 season.
- The court held Barnett breached that obligation by contracting to play for the Cleveland Pipers for the same period.
- The court granted injunctive relief restraining Barnett from playing for the Pipers and restraining the Pipers from employing him for the 1961–62 season.
- The injunction was limited to the season covered by the obligation and was to be dissolved after the 1961–62 season.

## Legal Principles

- A properly exercised renewal/option clause in a professional player contract can bind the player for the option year and preclude inconsistent employment during that term.
- Courts generally will not order specific performance of a personal-services contract, but may enforce a negative covenant by restraining the athlete from performing for a competitor during the contract period.
- Injunctive relief is appropriate where the services are shown to be special and non-fungible and where damages are not an adequate remedy.
- Equitable restraints should not exceed the temporal scope of the underlying contractual obligation.

## Conclusion

The court enforced Syracuse’s claimed contract right for the 1961–62 season and, without compelling performance for Syracuse, barred Barnett from playing for a rival club and barred the rival club from employing him during that season, with the restraint ending when the season concluded.


Cent. N.Y. Basketball, Inc. v. Barnett, 181 N.E.2d 506 (Ohio C.P. 1961)