Dryer v. Los Angeles Rams

In Dryer v. Los Angeles Rams (1985) 40 Cal.3d 406, the plaintiff Fred Dryer and a professional football team entered into an employment contract with an arbitration clause. Later, when he was removed from the active roster, Dryer sued the team and four individuals for breach of contract. The complaint specifically alleged that each defendant was a party to the contract and each defendant breached it, even though the individual defendants had not signed the contract. (Dryer,supra, 40 Cal.3d at p. 418.) The trial court found that each cause of action alleged in the complaint was included in and governed by the contract. (Ibid.) Under those circumstances, the California Supreme Court held that if, as the complaint alleged, the individual defendants were acting as agents for the football team, then they would be entitled to the benefit of the arbitration clause contained in the contract they allegedly breached. (Ibid.) In that case, the plaintiff sued a football team (the Rams) and four individuals for breach of his employment contract. The defendants petitioned to compel arbitration pursuant to a provision in that contract which called for arbitration of disputes involving interpretation or application of any contract provisions. The trial court denied the petition as to the individual defendants, on the ground they were not signatories to the contract. The appellate court reversed. The complaint alleged three of the individual defendants were sued in their capacities as operators and managing agents of the Rams. (Id. at p. 418.) It alleged all four were parties to the contract and breached it; the trial court found each cause of action was governed by the contract. The appellate court concluded: "If it is true that all of the significant issues in this suit arise out of the contract or the alleged breach of contract, and if the trial court correctly concluded that the individual defendants are not parties to the contract (presumably because they were not signatories), then it is not clear that these defendants belong in this suit at all. If, as the complaint alleges, the individual defendants, though not signatories, were acting as agents for the Rams, then they are entitled to the benefit of the arbitration provisions." (Id. at p. 418.) The court concluded the claims against the individual defendants should be referred to arbitration (Ibid.) In sum, in Dryer v. Los Angeles Rams (1985) a football player sued his team (the Los Angeles Rams) and four agents, alleging three of the four agents were sued in their capacities as owners, operators, and managing agents of the Rams, and that all four of the individuals were parties to (and had breached) the player's contract with the Rams. The agents were nonsignators to the player's contract with the Rams. The agents and the Rams petitioned to compel arbitration and affirmatively accepted the player's characterization of their status and connection to each other. In that context, the Supreme Court said the agents were "entitled to the benefit of the arbitration provisions." (Id. at p. 418.)