Football Player's Lawsuit Against His Team in California

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 having an arbitration clause. When Dryer was later removed from the active roster, he sued the team and four individuals for breach of contract. The complaint specifically alleged 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 each cause of action alleged in the complaint was included in and governed by the contract. (Ibid.) 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.) The plaintiff filed a lawsuit against the Rams, as well as individuals sued in their capacities as " 'owners, operators, managing agents, and in control sic of' " the Rams, under a contract containing an arbitration provision. (Id. at pp. 409-410, 418.) The individual defendants were alleged to have been party to the contract and breached the contract. (Id. at p. 418.) The trial court denied a petition to compel arbitration as to the individual defendants, on the ground they were not signatories to the contract. (Id. at pp. 411, 418.) The Court of Appeal reversed, holding that: "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.)