Dan Smith Softball v. Cayton

Background

Dan Smith Softball sued Daniel L. Cayton for breach of contract, seeking damages and injunctive relief. The plaintiff is a semi-professional softball team and sole proprietorship headquartered in San Jose, California. Cayton is a professional softball player residing in Casper, Wyoming. Both participated in a competitive league organized and run by the United States Specialty Sports Association.

The plaintiff alleged that it paid another team $75,000 for the right to recruit Cayton and that Cayton played for the plaintiff during the 2019 World Series. After that season, the parties entered into a written contract under which Cayton allegedly agreed to play exclusively for the plaintiff during the 2020, 2021, and 2022 seasons, with a guaranteed minimum payment exceeding $15,000 per year. The contract itself was not in the court’s record.

The plaintiff alleged that Cayton later decided to play for Resmondo and had played for that team in at least two tournaments. The plaintiff sought a temporary restraining order, which is emergency relief that can be issued before the opposing party is heard, and a preliminary injunction, which is relief that can remain in effect while the case proceeds.

Court’s analysis

The court explained that contracts for personal services generally cannot be specifically enforced because a person ordinarily cannot be forced to work. But under California law, an injunction may prevent a person from providing unique personal services to someone else when the services are covered by a written contract and cannot be adequately compensated with money.

The court found that Cayton’s services qualified as special, unique, unusual, and extraordinary because he was a talented and highly ranked softball player in the league. The plaintiff was not asking the court to force Cayton to play for its team; it sought only to stop him from playing for other teams.

The court also considered whether the plaintiff showed immediate and irreparable injury, meaning harm that could not adequately be remedied with money and would occur before Cayton could respond. The court agreed that alleged losses involving reputation, morale, attendance, and playoff and World Series chances would be difficult to quantify financially. However, the plaintiff had not shown that a tournament was scheduled soon enough to require emergency relief before a hearing. The court also stated that it was unclear whether a reduced chance of winning the World Series qualified as an injury supporting injunctive relief.

Ruling

The court granted in part and denied in part the plaintiff’s application. It denied the request for a temporary restraining order because the plaintiff had not demonstrated an immediate risk of injury before Cayton could be heard.

The court granted the request for an order to show cause. Cayton was ordered to explain why a preliminary injunction should not prevent him from playing for Resmondo or any other team in the league. The order set deadlines for Cayton’s response and the plaintiff’s reply and scheduled a hearing for August 14, 2020, by video conference. Judge Edward J. Davila signed the order.