## Facts

- A limited partnership was formed to exploit and profit from heavyweight champion George Foreman’s boxing career and related commercial activities.
- Foreman, his manager/trainer Charles R. Sadler, and the partnership’s general partner entered into a 1972 agreement governing Foreman’s boxing performances and promotional activities.
- The agreement gave the partnership significant control over fight-related financial arrangements and participation in the exploitation of Foreman’s name and services, in exchange for a percentage of Foreman’s revenues.
- Foreman and Sadler later asserted the agreement functioned as a boxing “manager” contract under California’s boxing regulatory scheme and was illegal because it was not approved by the California State Athletic Commission and exceeded statutory/regulatory limits.
- During the dispute, the parties stipulated to a preliminary injunction that placed bout proceeds into restricted accounts pending resolution; the partnership later sought contempt findings for alleged violations.

## Issues

1. Whether the 1972 agreement constituted a manager–boxer contract regulated by California’s boxing statutes and the California State Athletic Commission.
2. If so, whether noncompliance with Commission approval requirements and limits on duration/control/compensation rendered the agreement void and unenforceable.
3. Whether a court may grant injunctive relief compelling performance of an illegal agreement.
4. Whether restitution is available for advances and expenditures made under an illegal agreement to prevent unjust enrichment.

## Decision

- The court held the 1972 agreement was illegal and unenforceable under California law.
- The partnership was treated as a “manager” because the contract granted substantial managerial control and tied compensation to Foreman’s fight earnings.
- Because the agreement was not approved by the Commission and violated regulatory limits on manager contracts, the court refused to enforce it and denied preliminary injunctive relief compelling performance.
- The court nevertheless ordered restitution requiring Foreman and Sadler to reimburse the partnership for advances and expenditures not already recouped from Foreman’s earnings.
- The court reserved decision on contempt relating to the earlier stipulated injunction and set the matter for hearing.

## Legal Principles

- An entity that exercises substantial control over a boxer’s career and finances and shares in bout revenues may be treated as a “manager” subject to boxing regulation, regardless of organizational form.
- A contract that violates a detailed regulatory scheme designed to govern boxer–manager relationships (including required Commission approval and limits on duration/control/compensation) is void and unenforceable as against public policy.
- Courts will not grant specific performance or injunctive relief to compel performance of an illegal contract.
- Even when a contract is illegal and unenforceable, a court may award limited restitution for unrecovered advances to prevent unjust enrichment, so long as the remedy does not materially frustrate the regulatory policy.

## Conclusion

The court determined the 1972 agreement operated as an unapproved and noncompliant manager–boxer contract under California law, making it void and barring injunctive enforcement, while permitting restitution to repay unrecovered advances and reserving contempt issues for later proceedings.


George Foreman Assocs., Ltd. v. Foreman, 389 F. Supp. 1308 (N.D. Cal. 1974)