Oakland Raiders v. Nat'l Football League - 131 Cal. App. 4th 621, 32 Cal. Rptr. 3d 266 (2005)

Rule:

A fiduciary relationship is a recognized legal relationship such as guardian and ward, trustee and beneficiary, principal and agent, or attorney and client. A fiduciary must give priority to the best interest of the beneficiary. In addition to this duty of preference toward the beneficiary, the fiduciary also is required to manage the subject matter of the relationship (or res) with due care, must account to the beneficiary, and must keep the beneficiary fully informed as to all matters pertinent to the beneficiary's interest in the rest.

Facts:

Plaintiff, Oakland Raiders, a professional football league and a member club of an unincorporated association known as the National Football League, herein defendant. Plaintiff sued defendants- the league and its commissioner, alleging that defendants breached their fiduciary duty to the club. Plaintiff claimed that it was discriminated against and treated unfavorably by defendants as compared with the other member clubs, thereby placing it at a competitive disadvantage. Defendants argued that this claim was without merit for a variety of reasons, including the absence of legal duty, and the requirement that courts abstain from involving themselves in disputes involving private voluntary associations. The trial court granted summary adjudication in favor of defendants. Plaintiff then appealed. 

Issue:

Did the defendants breach their fiduciary duty to plaintiff?

Answer:

No. The judgment was affirmed

Conclusion:

The instant court held that neither defendant stood in a fiduciary relationship with the plaintiff. The relationship between the plaintiff, on one hand, and the defendants, on the other hand, was not one under which a fiduciary relationship existed as a matter of law. There was no merit to the plaintiff's claim for breach of fiduciary duty arising out of a joint venture. There was no fiduciary relationship between defendants and the plaintiff arising either as a result of agreement or by operation of law. The breadth of the defendant commissioner's powers plainly showed that there were numerous and varied potential circumstances in which the commissioner could be required to act against the best interests of the club. The trial court properly concluded that it was barred by the abstention doctrine from resolving the dispute between the plaintiff and defendants. The trial court also properly rejected plaintiff's additional claims, both because they were not pleaded, and because they were without merit as a matter of law.