Dan Smith Softball v. Cayton

Background

Dan Smith Softball, a semi-professional softball team and sole proprietorship headquartered in San Jose, California, sued Daniel L. Cayton for breach of contract. The team alleged that, after paying another team $75,000 for the right to recruit Cayton, it entered into a written agreement with him requiring him to play exclusively for Dan Smith Softball during the 2020, 2021, and 2022 seasons. The team represented that the agreement guaranteed Cayton more than $15,000 per season, although the contract itself was not in the record before the court.

The team alleged that Cayton instead played for a competing team, Resmondo, in at least two tournaments during the delayed 2020 season. It sought a temporary restraining order and a preliminary injunction—court orders restricting conduct while a case is pending—to prevent Cayton from playing for Resmondo or any other team in the league.

Legal Standard

Under Federal Rule of Civil Procedure 65, a temporary restraining order issued without notice requires specific facts showing that immediate and irreparable injury will occur before the opposing party can be heard, along with a written certification by the moving party’s lawyer regarding efforts to provide notice and the reasons notice should not be required.

The court explained that contracts for personal services generally cannot be specifically enforced because a person cannot be forced to continue working. But courts may enforce a negative promise—an agreement not to provide services to someone else—when the services are special, unique, unusual, extraordinary, or otherwise difficult to replace. California law recognizes this exception for certain written personal-services contracts.

Court’s Analysis

The court found that Cayton’s services could fall within this exception because he was a talented and highly ranked player in the United States Specialty Sports Association league. Dan Smith Softball did not seek to force Cayton to play for its team; it sought only to prevent him from playing for other teams. The court concluded that the reasoning supporting restrictions on competing services could apply to this situation.

The court nevertheless required a showing of immediate irreparable injury. Dan Smith Softball argued that Cayton’s continued play for a competitor would harm its competitive position, reputation, attendance, team morale, and chances of reaching or succeeding in the playoffs. The court agreed that some of those injuries might be difficult to measure with money. But it found that the motion did not show that a tournament was scheduled soon enough to justify an emergency order before Cayton could be heard. The court also stated that it was unclear whether a reduced chance of winning the World Series qualifies as an injury supporting injunctive relief.

Disposition

The court granted Dan Smith Softball’s 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 another team in the league. The court denied Dan Smith Softball’s request for a temporary restraining order. It set deadlines for Cayton’s response and the team’s reply and scheduled a hearing for August 14, 2020, by videoconference. The order addressed the requested interim relief and did not resolve the underlying breach-of-contract claim.