## Facts

- Jack Molinas, a professional basketball player, signed a standard NBA player contract with the Fort Wayne Zollner Pistons that incorporated the NBA Constitution and By-Laws.
- The uniform contract contained an anti-gambling provision stating that a player who directly or indirectly bet on NBA games was subject to expulsion or suspension under league procedures.
- In January 1954, during a police inquiry into gambling involving Pistons players, Molinas signed a statement admitting he had wagered on games involving his own team.
- Maurice Podoloff, the NBA President, imposed an indefinite suspension barring Molinas from playing in the NBA.
- Molinas sued in New York Supreme Court seeking (i) an injunction vacating the suspension and restoring his status and (ii) damages for lost salary from the suspension date until any hearing.
- Molinas argued the league failed to provide the contractually required notice and hearing before discipline and that the President lacked authority to impose an indefinite (effectively permanent) suspension.

## Issues

1. Whether the suspension was invalid because it was imposed without the contractually contemplated notice and hearing procedures.
2. Whether the NBA Constitution, By-Laws, and uniform player contract authorized the NBA President to impose an indefinite suspension for wagering on NBA games.
3. Whether a court should grant injunctive relief interfering with a private sports league’s internal discipline where the player’s contractual consent and admitted misconduct were not meaningfully disputed.

## Decision

- The court denied Molinas’s request for injunctive relief and declined to set aside the suspension.
- The court treated the NBA’s disciplinary authority as arising from Molinas’s contractual agreement to the league’s rules and disciplinary machinery.
- Given Molinas’s written admission of betting on games involving his team, the court found the league’s discipline within authorized powers and not a proper basis for judicial intervention.

## Legal Principles

- A professional sports league’s disciplinary authority over a player may rest on contractual consent, where the player contract incorporates league constitutions, by-laws, and disciplinary provisions.
- Courts generally avoid interfering with internal discipline of private, voluntary associations when actions are taken under agreed rules and are not arbitrary, in bad faith, unlawful, or against public policy.
- Admitted wagering on league games, especially involving one’s own team, supports severe discipline (including suspension or expulsion) as a legitimate measure to protect the integrity of competition.
- Clauses requiring notice and hearing may not compel courts to overturn discipline where the violation is conceded and the sanction falls within the league’s contract-based authority.

## Conclusion

The court refused to enjoin the NBA President’s indefinite suspension of Molinas, reasoning that Molinas’s contract bound him to the league’s anti-gambling rules and disciplinary system and that, in light of his admitted wagering on games involving his team, the league’s action was within its contractual authority and not subject to judicial reversal.


Molinas v. Podoloff, 133 N.Y.S.2d 743 (Sup. Ct. N.Y. Cnty. 1954)