Sample v. Gotham Football Club

Professional football player Johnny Sample (plaintiff) and the Gotham Football Club, Inc. (Gotham) (defendant), which owned the New York Jets (club), signed three separate documents that were styled as one-year contracts for Sample to play for the club in the 1968, 1969, and 1970 National Football League (NFL) seasons. The document styled as the 1970 contract required Gotham to pay Sample his salary if he were to suffer an injury “during the term of this contract” that rendered him unable to perform his obligations under “this contract.” The club released Sample in 1969 after he suffered an injury. Sample sued Gotham, seeking, among other things, to enforce the 1970 contract’s injury-benefit provision, arguing that although the parties executed three separate documents, he believed that he was agreeing to a single three-year contract. Sample further claimed that he was duped into signing separate documents due to his lack of sophistication and legal representation and Gotham’s superior bargaining power. Thus, Sample contended, he was entitled to receive the 1970 contract’s injury benefit despite having been injured in 1969. Gotham responded that the parties signed three separate contracts covering three different NFL seasons and that the 1970 contract’s injury-benefit provision applied only to an injury sustained during the period covered by “this contract” (i.e., 1970). Thus, Gotham argued, Sample’s 1969 injury did not qualify. Sample moved for partial summary judgment with respect to his claim to enforce the injury-benefit provision of the 1970 document.