## Facts

- An NFL player’s prior contract required repayment of part of a signing bonus if he voluntarily failed to play during a specified period.
- After a trade, the player signed a new contract with a different team that (a) paid performance-based incentives and (b) required refund of those incentives if he refused to play.
- The new contract incorporated the earlier signing-bonus repayment obligation by reference.
- In July 2004, the player announced his retirement, which the team and the league management council treated as a voluntary refusal to play triggering repayment.
- A grievance proceeded to arbitration under the NFL collective bargaining agreement (CBA), and the arbitrator awarded the team and management council $8,616,343 for repayment of signing-bonus and incentive amounts.
- The team and management council petitioned in federal court to confirm the arbitration award under the Federal Arbitration Act (FAA); the player and players’ association cross-moved to vacate.

## Issues

1. Whether the arbitration award should be confirmed under the FAA’s deferential standards for review of labor arbitration awards arising from a CBA.
2. Whether the award should be vacated because the arbitrator acted in manifest disregard of Florida law governing liquidated damages versus unenforceable penalties.
3. Whether enforcement of the award would violate an explicit, well-defined, and dominant Florida public policy against punitive contractual penalties.

## Decision

- The court granted the motion to confirm the arbitration award and denied the cross-motion to vacate.
- The court found no FAA statutory ground for vacatur (e.g., corruption, fraud, evident partiality, misconduct, or exceeding arbitral powers).
- The court held the player failed to show manifest disregard of the law because, at most, he alleged legal error rather than a knowing refusal to apply controlling law.
- The court rejected the public-policy challenge because the asserted policy did not meet the narrow requirement of being explicit, well-defined, and dominant, and the argument largely recharacterized a disagreement with the arbitrator’s contract and damages analysis.

## Legal Principles

- FAA review of arbitration awards is highly limited; confirmation is required absent a proven statutory basis for vacatur.
- In labor arbitration tied to a CBA, courts give strong deference and do not re-decide contract interpretation so long as the arbitrator was arguably construing and applying the agreement within delegated authority.
- “Manifest disregard of the law” requires more than misapplication or misunderstanding; it requires proof the arbitrator knew controlling law and intentionally ignored it.
- The public-policy exception to enforcement of a labor arbitration award applies only where enforcement would violate an explicit, well-defined, and dominant public policy grounded in positive law.

## Conclusion

The court confirmed an $8.6 million NFL labor-arbitration award enforcing contractual repayment provisions triggered by the player’s retirement, holding that neither FAA vacatur grounds, manifest disregard of Florida law, nor a qualifying Florida public policy barred enforcement.


Miami Dolphins, Ltd. v. Williams, 356 F. Supp. 2d 1301 (S.D. Fla. 2005)