Williamson v. Prime Sports Mktg., LLC, No. 1:19-cv-00593, 2021 WL 201255 (M.D.N.C. Jan. 20, 2021)

Facts

  • Zion Williamson, then a Duke University basketball player, signed a written agreement granting Prime Sports Marketing, LLC and its president, Gina Ford, exclusive authority to represent him for marketing and professional sports opportunities.
  • At signing, Williamson was enrolled at Duke, competing in intercollegiate athletics, and had not been declared permanently ineligible by any collegiate governing body.
  • North Carolina’s Uniform Athlete Agents Act (UAAA) required athlete-agent registration before contracting with a student-athlete and required the contract to include specified, conspicuous warnings about potential loss of eligibility.
  • Ford/Prime were not registered as athlete agents in North Carolina, and the agreement lacked the required warning language.
  • Williamson terminated the agreement and sought declaratory relief that it was void under the UAAA; defendants argued the UAAA did not apply because Williamson allegedly had already engaged in conduct that would have made him permanently ineligible under NCAA rules.

Issues

  1. Whether Williamson qualified as a “student-athlete” under the North Carolina UAAA when the agreement was executed.
  2. Whether noncompliance with the UAAA’s registration and warning-language requirements rendered the agreement void as a matter of law on the pleadings.
  3. Whether post-judgment relief and leave to amend were warranted based on alleged legal error or additional allegations about Williamson’s purported ineligibility.

Decision

  • The court granted Williamson’s Rule 12(c) motion for partial judgment on the pleadings.
  • The court held Williamson was a “student-athlete” under the UAAA at the time of contracting because he was participating in intercollegiate athletics and had not been declared permanently ineligible.
  • The court declared the agreement void and unenforceable because Ford was unregistered in North Carolina and the agreement omitted the UAAA’s required warnings.
  • In a later order, the court denied defendants’ motions to alter/amend or vacate and denied leave to amend, finding no clear legal error and concluding amendment would be futile.
  • Under the North Carolina UAAA, a person participating in intercollegiate athletics who has not been declared permanently ineligible qualifies as a “student-athlete” for purposes of the Act.
  • Conclusory allegations that a student-athlete would have been permanently ineligible under NCAA rules, absent an actual declaration of permanent ineligibility, do not remove the athlete from the UAAA’s coverage at the pleading stage.
  • An athlete-agent contract covered by the UAAA is void if the agent is not properly registered in North Carolina and the contract lacks the statutorily required warning language.
  • Post-judgment relief requires more than reargument; leave to amend may be denied as futile where proposed allegations would not change the statutory analysis or plausibly establish a dispositive fact.

Conclusion

The court applied the North Carolina UAAA’s text to hold that Williamson was a protected student-athlete when he signed the agency agreement, and it declared the agreement void because the agent was unregistered and the contract omitted mandatory eligibility warnings; it later refused to reopen the ruling or allow amendments that would not alter that result.