| Lacrosse players join ex-golfer's lawsuit; friend-of-the-court brief | |
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| Topic Started: Jun 20 2009, 07:39 AM (1,606 Views) | |
| Baldo | Jun 21 2009, 08:52 AM Post #16 |
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1.The Recommendation is Contradicted By Well-Settled Principles of North Carolina Contract Law The Magistrate’s error is a mistake of law; he confuses the law of indefinite contracts (which appears to have led him down the blind alley of Boyce and Brooks) with the law of illusory contracts. “The general rule in North Carolina, where a contract confers on one party a discretionary power affecting the rights of the other party, is that such a contract is not illusory so long as its interpretation is exercised in an objectively reasonable manner based upon good faith and fair play.” MCI Constructors, Inc. v. City of Greensboro, 125 Fed. Appx. 471, 477 (4th Cir. 2005) (emphasis supplied). And, as this Circuit has already recognized, North Carolina courts are deeply reluctant to invalidate a contract on the grounds that it is illusory. See, e.g. id. In MCI, the Fourth Circuit explained that, under North Carolina law, since an otherwise illusory promise is interpreted by the courts “as requiring a performance which must be satisfactory ... in the exercise of honest judgment, such contracts have been almost universally upheld.” Id. (quoting 13 Williston on Contracts § 38:21, at 458- 60 (4th ed. 2000) (footnotes omitted)); see also Fulcher v. Nelson, 273 N.C. 221, 159 S.E.2d 519 (N.C. 1968). Thus, any “unqualified” or “unilateral” right reserved to a party to a contract is limited by an implied limitation that the party must exercise the right in an objectively reasonable manner. MCI, 125 Fed. Appx. at 477. This rule is applied liberally so long as, “from the language of the contract, it is doubtful whether the parties intended that one party should have the unqualified option to terminate it in case of dissatisfaction” but instead “the intention was to give the right to terminate only in the event of dissatisfaction based upon some reasonable ground." Id. (internal citations and quotation marks omitted) (emphasis supplied) (quoting Fulcher, 273 N.C. at 221, 159 S.E.2d at 519). In this way, even a contract that appears to reserve to one party the “unilateral” or “unqualified” right to terminate the contract or modify its terms, "the contract will be construed as not reposing in one of the parties the arbitrary or unqualified option to terminate it" and it will be enforced as such. MCI, 125 Fed. Appx. at 477. Thus, the North Carolina courts do not invalidate a contract that allows a party to unilaterally amend it; instead they simply infer that the right must be exercised reasonably. The only exception to that rule (i.e., when the terms expressly preclude an implied limiting term) does not apply there because the text does not preclude limiting implied terms. 2.The Magistrate Failed to Look Behind the Defendants’ Ellipses to See That It Conceals the Very Words That Undermine Their Contention. Following the Defendants’ lead, the Magistrate’s M&R employs an ellipsis to mask the glaring defect in their assertion that the policy manuals are illusory because Duke reserves the right to unilaterally alter the “matters described herein without prior notice ....” M&R 8 (quoting the University Bulletin, (Compl. Exh. 7, at 5 )). The ellipsis conceals the final five words of the clause, and omitting them dramatically changes the legal significance of the quoted text. See Compl. Exh. 7, at 5. Unredacted, the entire sentence reads: The university reserves the right to change programs of study, academic requirements, teaching staff, the calendar, and other matters described herein without prior notice, in accordance with established procedures. Id. (emphasis supplied). Thus, the excised text shows that the right to “change” the “matters described” is neither unilateral nor unlimited at all. The ellipsis the University employed and the Magistrate subsequently used, concealed the words that expressly limit the right to change the Bulletin’s provisions; the right to “unilaterally change” may only be exercised “in accordance with established procedures.” Id. Thus, the right to change the University Bulletin does not establish that terms may be “conditioned upon the whim or caprice of the party” and the protections established therein are not therefore “given and taken in the same breath” as must be shown to render a contract illusory. MCI, 125 Fed. Appx. at 477; Kadis v. Britt, 224 N.C. 154, 163, 29 S.E.2d 543, 548 (N.C. 1944); see also Fulcher, 273 N.C. at 224, 159 S.E.2d at 522. Furthermore, in another resort to typographical sophism, the Defendants omit their quote of the same clause with the preceding sequence, which also dramatically limits the scope of the right to change the terms. The canon of construction ejusdem generis operates to limit the scope of the sequence ending in “and other matters” to only those things of the kind in the preceding list (i.e., academic concerns). Therefore, the Court need not even imply a limiting term of objective reasonableness, good faith, and fair play (as North Carolina law would otherwise require to save the manual from being illusory). The right to change the provisions is—on its face—duly limited and qualified on its own terms. Magistrate Dixon needed only to look and see what the Defendants’ ellipsis concealed. Having failed to do so, his recommendations now urge that this Court make the same oversight. The Court should decline that invitation and reject the M&R. That is ample reason to reject the Magistrate’s recommendation that the Court enter judgment on the pleadings, but there is more. Edited by Baldo, Jun 21 2009, 08:53 AM.
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| Baldo | Jun 21 2009, 09:00 AM Post #17 |
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3.The University Habitually Seeks (and Obtains) Orders from this Court and Others Compelling Enforcement of Provisions Contained in University Bulletins and Policy Manuals. In addition to all of the foregoing reasons, we know that the University’s policy manuals are enforceable—even when they expressly reserve the University’s right to unilaterally change them— because the University does it all the time—in this Court, no less. For example, the University’s own affidavits and memoranda, filed in this Court and others, contradict Defendants’ claim that the University’s policy manuals cannot be enforced as binding contracts. In fact, the University regularly contends that its dispute resolution policy is a “valid and binding arbitration agreement” that is enforceable in this and other courts. See, e.g., Evans Aff., Exh. A, at 10-14. That policy, is contained only in one of the University’s policy manuals, originally called the Staff Benefits Guide (“Guide”). As explained below, there is no meaningful distinction between the Guide and the policy manuals annexed to the Complaint. Just like the University Bulletin that Defendants claim is unenforceable in this case, the Guide contains an express reservation of the right to “unilaterally change” its provisions. A comparison of the relevant language is instructive: Student 2007-2008 Bulletin “The university reserves the right to change programs of study, academic requirements, teaching staff, the calendar, and other matters described herein without prior notice, in accordance with established procedures.” Compl. Exh. 7, at 5. Staff Benefits Guide “Certain policies, benefits, and services described in this handbook may be changed or discontinued. Booklets and plan descriptions summarizing various benefits, policies, and services are issued and revised from time to time. Official policy manuals and governing plans and agreements shall govern in all cases the terms and conditions applicable to the matters governed in this handbook.” Exh. A, at 53. Thus, both policy manuals plainly reserve to the University the right to “change” their contents; however, the Guide is broader—it includes the right to unilaterally “discontinue” the “policies, benefits, and services described in the handbook,” a right that is not in the policy manuals annexed to the Complaint. Nevertheless, despite an even broader right to “unilaterally change” the Guide and its arbitration policy, the University habitually demands that this Court and others must enforce it, over the strenuous objections of the University’s party-opponent. In fact, Duke has compelled judicial enforcement so often that North Carolina Superior Court Judge Howard Manning recently remarked that Duke has obtained “enough federal orders to choke a cow, from the Middle District and elsewhere, requiring Duke employees to arbitrate under the agreement ....” Exh. B, Transcript of the Motion at 2, Pressler v. Duke Univ., 08CVS 1311 (Durham Co. Sup. Ct. Apr. 16, 2008) (pending on appeal of the denial of Duke’s Motion to Compel enforcement of the Guide in N.C. Court of Appeals). Additionally, when the University is seeking to enforce provisions of the Guide, the University contends that the expressed right to unilaterally change the Guide at any time, actually expands Duke’s right to enforce not only the original arbitration policy but also its amended versions, expanding the policy’s enforceability. See, e.g., Evans Aff., Exh. A, at 10-14. Of course, the University’s position in those sworn affidavits and memoranda is the polar opposite of the position that Defendants have taken in this case. In this case, the University contradicts its own sworn affidavits by asserting that the right to unilaterally amend the documents annexed to the Complaint renders their provisions “unenforceable” as a matter of law. See, e.g., Motion 13-14. And, Magistrate Dixon recommends that this Court adopt this new position, which would call into question all of the orders issued on the contrary premise. When seeking to compel enforcement of its manuals, Duke contends that the reason for the statement establishing the right to unilaterally amend the manuals is to notify employees that they must be vigilant to keep abreast of its changes so that they may know the updated specifics of the agreement to which Duke contends, they are “contractually bound.” See, e.g., Evans Aff., Exh. A, at 10-14; Kornberg Aff., Exh. C, at 22-23; Memorandum Supporting Mot. to Compel § 2, Exh. D, at 5. To corroborate its contrary position in those cases, the University routinely files an affidavit sworn to by a senior University official. See, e.g., Evans Aff., Exh. A, at 10-14; Kornberg Aff., Exh. C, at 22-23. The affidavits are largely the same from case to case. To take one example, Denise L. Evans’ affidavit in Pressler v. Duke Univ. explained how the University notifies employees of unilateral changes it makes to the arbitration policy in the following way: 9.In July 1990, the Staff Benefits Guide stated that that the policies, benefits, and services described in the handbook may be changed and that booklets and plan descriptions summarizing benefits, policies, and services are issued and revised from time to time. 10.Effective September 15, 2005, Duke's dispute resolution procedures were amended to create more opportunities to resolve issues informally at the department level. The amended procedure thereafter applied to both exempt and non-exempt employees of Duke. A true and correct copy of the Dispute Resolution Policy that was in effect at the time of Mr. Pressler's separation from employment at Duke in April 2006 is attached to this affidavit at Exhibit F. 11.Duke notified its employees that the dispute resolution procedures were amended by issuing a news release from the Office of Human Resources. Duke also published notice of the amendments in three publications that are readily available to Duke employees: (1) the Duke Dialogue, (2) Inside Duke University Medical Center & Health System, which is an employee newsletter, and (3) The Chronicle, which is a Duke newspaper. True and accurate copies of the news release and these notices are attached as Exhibit G to this affidavit. 12.During the time period from July 1990 through the present date, the Dispute Resolution Procedure or Dispute Resolution Policy, as it was variously titled during that period, contained a provision for final and binding arbitration. Evans Aff., Exh. A, at 10-14, Pressler, 08CVS131 1 (Durham Co. Sup. Ct. filed with Defs.’ Mot. Stay Proceedings Pending Arb. on March 11, 2008) (emphasis supplied). It is also worth noting that Duke is demanding enforcement of its Guide provisions even after Coach Pressler and Duke signed an agreement that terminates “all” prior agreements between them. See Exh. B, Transcript of the Motion 23-25, Pressler v. Duke Univ., 08CVS1311 (Durham Co. Sup. Ct. 2008). A collection of file materials relating to the University’s motion to compel enforcement of its policy manual(s) are annexed to these Objections. All of the file materials related to Duke’s motion to compel enforcement of its policy manual(s) in Pressler v. Duke are annexed hereto as Exhibit A; the file materials related to the same motion in Moye v. Duke Univ. Health Sys., Inc., 06CV00337,(M.D.N.C. 2006) are annexed hereto as Exhibit C; the file materials related to the same motion in Whitehead v. Duke Univ. Med. Ctr., 05CV641-F(3) (E.D.N.C. 2005) are annexed hereto as Exhibit D. An additional collection of federal orders and memorandum opinions enforcing the University’s policy manuals are annexed to these Objections as Exhibit E. All of the foregoing makes clear what this Court already knows: the University routinely enforces its bulletins when their provisions favor the University; and the provisions in those bulletins are routinely enforced by this Court. They are not nullified, held illusory, or otherwise invalid because they may be unilaterally changed without notice. The University’s argument does not suffer for lack of gall; and in light of the litany of sworn affidavits and memoranda on file with this Court, denying this Motion is insufficient to fully address the University’s unsupported and contradictory assertions in this case. Edited by Baldo, Jun 21 2009, 09:14 AM.
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| Baldo | Jun 21 2009, 09:09 AM Post #18 |
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C. PLAINTIFF’S CLAIM FOR DECLARATORY RELIEF DOES NOT DEPEND ON THE EXISTENCE OF A CONTRACT. Magistrate Dixon recommends entry of judgment on Plaintiff’s claim for declaratory relief. His Recommendation does not assert that the Complaint is insufficient with respect to Plaintiff’s declaratory judgment claim, nor could he. The Complaint makes very clear that the relief Plaintiff seeks in this action is a clear judicial declaration of the rights and responsibilities that exist between Duke University and its students. See, e.g., Compl. ¶¶ 56, 105 - 106. In light of the spate of lawsuits recently brought by students against their University in this Court alone, the need for clarification on the legal relationship between the University and its students and Division I coaches and their student-athletes is plainly obvious. The Defendants’ briefing only makes the need even more obvious. And, here again, the Recommendation misses the mark by dispensing with Plaintiff’s claim by stating, “no valid contract means no declaratory judgment.” M&R 11. The Magistrate’s statement, however, is contradicted by the text of the Declaratory Judgment Act itself, and the only authority the Magistrate cites to support the proposition impugns him The Magistrate does not conclude that the pleadings are insufficient with respect to Plaintiff’s declaratory judgment claim, nor could he. The Complaint makes very clear that the relief Plaintiff seeks in this action is a clear judicial declaration of the rights and responsibilities that exist between Duke University and its students. See, e.g., Compl. ¶¶ 56, 105 - 106. 1.The Declaratory Judgment Act Expressly Authorizes Relief Where No Other Relief Is or Could Be Sought. The Declaratory Judgment Act plainly authorizes the remedy of declaratory relief “whether or not further relief is or could be sought.” 28 U.S.C. 2201 (2009). The Act is straightforward; it does not require that a plaintiff first establish a right to any other form of relief. Thus, contrary to the Magistrate’s assertion, “no valid contract” does not “mean[] no declaratory judgment.” The Magistrate’s conclusion that Plaintiff has failed to state a claim for declaratory relief is wrong because its premise is false. As such, the Court should reject it. The Act empowers this Court to provide declaratory relief in any “actual controversy within its jurisdiction.” Id. This Circuit has interpreted the statute’s broad authorization to include any case in which a declaratory judgment “will serve a useful purpose in clarifying and settling the legal relations in issue,” and “will terminate and afford relief from the uncertainty, insecurity, and controversy giving rise to the proceeding.” Aetna Cas. & Sur. Co. v. Quarles, 92 F.2d 321, 325 (4th Cir. 1937) (cited with continuing approval in Mut. Benefits Ins. Co. v. Lorence, 59 Fed. Appx. 595, 597 (4th Cir. 2003)). In addition, this Circuit has long held that the discretion afforded by the statute “should be liberally exercised to effectuate the purposes of the statute and thereby afford relief from uncertainty and insecurity with respect to rights, status and other legal relations.” Quarles, 92 F.2d at 324 (citing Edwin Borchard, Declaratory Judgments, 101). As a result, contrary to the Magistrate’s suggestion, Plaintiff has stated claims for declaratory relief in the wide sweep of contexts in which “actual controversies arise.” See, e.g., Duke Power Co. v. Carolina Envtl. Study Group, Inc., 438 U.S. 59 (1978) (declaratory judgment claim to contest the constitutionality of anticipated governmental action before damages are sustained); Younger v. Harris, 401 U.S. 37 (1971) (seeking declaration that the California Criminal Syndicalism Act, Cal. Penal Code §§ 11400 and 11401, was unconstitutionally vague and overbroad); Horace Mann Ins. Co. v. General Star Nat. Ins. Co., 514 F.3d 327 (4th Cir. 2008) (declaratory judgment to determine nature and scope of insurance contracts).5 Thus, the existence of a “valid contract” is not a precondition to declaratory relief, and this recommendation, like the others, is invalid. 2.The Authority the Magistrate Relies Upon Contradicts Him. To support the assertion that “no valid contract means no declaratory judgment,” M&R 11, Magistrate Dixon relies on Shelton v. Duke Univ. Health Sys., Inc., 633 S.E.2d 113, 117 (N.C. Ct. App. 2006). However, a careful reading of Shelton reveals that the case contradicts the assertion. The court in Shelton held that dismissal of a claim for a declaratory judgment is proper where, in the course of adjudicating the motion to dismiss, the court clarifies and settles the rights and responsibilities of the parties. See id. In addition, Shelton ruled that a contract existed between the parties, id. at 114-117, and therefore did not hold there was “no valid contract” at step one, id. After holding that a valid contract existed, the court identified the material terms of the contract and held that there was no ambiguity left to resolve. Id. at 114-115. Finally, the court in Shelton held that dismissal of Plaintiff’s declaratory judgment was proper because the plaintiff sought declaratory relief to resolve ambiguity in the price term of the contract, and the Court found that the price term was not ambiguous and the plaintiff had paid it. Id. at 117. Shelton simply does not support the recommendation; in fact, by implication, Shelton contradicts it. Because the Magistrate’s recommendation on Plaintiff’s declaratory relief claim is contradicted by both the text of the Declaratory Judgment Act and because the only authority offered to support the recommendation contradicts it, the Court should reject the recommendation. REQUEST FOR LEAVE TO AMEND To the extent that Plaintiff’s allegations are deemed insufficient with respect to any of the claims asserted in the Complaint (or require the elaboration or clarification otherwise provided in Plaintiff’s briefing on the Motion or in these Objections), Plaintiff respectfully requests that the Court grant Plaintiff leave to amend the complaint pursuant to Rule 15 of the Federal Rules of Civil Procedure. CONCLUSION For all of the foregoing reasons, the Court must reject the Recommendation. In the alternative, Plaintiff requests leave to amend the complaint to cure any ambiguity or insufficiency the Court may find in the Complaint. Dated: June 18, 2009 Respectfully submitted, EKSTRAND & EKSTRAND LLP /s/ Robert C. Ekstrand Edited by Baldo, Jun 21 2009, 09:10 AM.
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| Baldo | Jun 21 2009, 09:13 AM Post #19 |
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Note! There are over 300 plus pages of supporting documentation. We will just have to wait for Justia for those. Again there may be typos from my PDF translation, but this gives you an idea what the filing is about. |
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| Baldo | Jun 21 2009, 02:14 PM Post #20 |
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After reading through this it seems to me that a door has been kicked open in how does Duke handle lawsuits against them. In some cases they claim arbitration and in others deny it. The manuals, handbooks that Duke provides are used when it suits them and then denied when it opens the door to a potential arbitration and eventually, a jury trial. The attached documents clearly show this in court filings, depositions, and handbooks. Duke wants to have it both ways, long as it suits them. Who would have thought the Giuliani Lawsuit would have opened this door? Edited by Baldo, Jun 21 2009, 02:15 PM.
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| brittany | Jun 21 2009, 02:32 PM Post #21 |
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Does anyone really think 38 players got involved without their attorney's approval?
Edited by brittany, Jun 21 2009, 02:33 PM.
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| Joan Foster | Jun 21 2009, 02:38 PM Post #22 |
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So all these expensive Duke lawyers are arguing one thing in one case...the opposite in the next. Today the handbook is binding; tomorrow it is not. Hmmm.. That's one crackerjack operation. |
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| abb | Jun 21 2009, 04:22 PM Post #23 |
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The elephant in the room is this clown magistrate. No minister of justice has any Goddamned business writing in legal document the crap he did. It demeans the law, if any such thing is further possible in North Carolina. |
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| Baldo | Jun 22 2009, 11:33 AM Post #24 |
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Sounds like Duke's General Counsel Office screwed up to me. They didn't co-ordinate the various legal strategies. |
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| nyesq83 | Jun 22 2009, 12:00 PM Post #25 |
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Worst of all, he wasn't even the least bit amusing. |
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| Acc Esq | Jun 22 2009, 01:32 PM Post #26 |
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Maybe Dean Sue is overseeing all this litigation? |
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| Joan Foster | Jun 22 2009, 01:54 PM Post #27 |
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Nifong has a lot of time on his hands...maybe he's volunteering. |
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| Baldo | Jun 22 2009, 01:54 PM Post #28 |
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Well with the world's greatest self-proclaimed former, disgraced, and disbarred DA/Attorney at the center of four lawsuits one can expect screw ups. The biggest mistake Duke ever did was to lay down with Nifong and now they are full of fleas. Who knows maybe Duke's General Counsel has adopted the Nifong's Legal Strategy. "Put your hands over your ears and don't read the files!" Edited by Baldo, Jun 22 2009, 06:27 PM.
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| sdsgo | Jun 23 2009, 09:46 AM Post #29 |
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The plaintiff objects to Magistrate Judge Dixon’s recommendation for dismissal from two independent perspectives. First, Mr. Andrew Giuliani claims that Duke violated it own policy manuals, when he was removed from the golf team, and second, that Duke independently breeched an oral contract between Coach Myers and Mr. Giuliani to provide lifetime access to Duke’s state-of-the-art golf training facilities. To facilitate later discussion on the oral contract, I’m providing two background links. Mr. Ekstrand relies on a 1918 N.C. Supreme Court decision to defend Andrew’s claim that the oral contract was valid. You can read the decision in the Southeastern Reporter. Wilkins v. Vass Cotton Mills, 176 N.C. (1918) Also, a recent WRAL post provides a relevant description of current NC law on when a contact must be in writing. ‘Let’s shake on it’: Understanding when a handshake and an oral contract just doesn’t cut it eta: Recruitment Offers - All sports: You are not eligible if, before you enrolled at your institution, any staff member of your institution or any other representative of your institution's athletics interests provided or offered to you, your relatives or your friends any financial aid or other benefits that NCAA legislation does not permit. It is permissible for your summer employment to be arranged by the institution or for you to accept educational loans from a regular lending agency provided you did not receive the job or loan before the end of your senior year in high school. [Bylaws 13.2.1, 13.2.4 and 13.2.5] The National Collegiate Athletic Association June 29, 2005 Source: 2005 NCAA Regulations Edited by sdsgo, Jun 23 2009, 10:25 AM.
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| sdsgo | Jun 24 2009, 02:37 PM Post #30 |
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Ekstrand’s Catch-22 Did Andrew Giuliani’s attorney harm his client by arguing that “Coach Myers’ recruiting offer included a promise of a … lifetime right of access to its “state of the art” golf training facilities, and other valuable consideration.”? A rigorous review of the 2005 NCAA Policy Manual indicates that may well be the case. In their Answer, Duke emphatically denies that ‘Coach Myers told ANDREW GIULIANI that ANDREW GIULIANI “would be given life-time access to those training facilities as an alumnus of the Duke Golf Program,” as this is a privilege never given to any student at or graduate of DUKE UNIVERSITY.’ (Paragraph 13) But for the purpose of the current motion, we must assume the validity of any plausible assertions. Lifetime right of access to “state of the art” golf training facilities would be a significant benefit. A typical commercial consumer would have to pay thousands of dollars per year and as much as a hundred thousand dollars over a lifetime for such access. So we must ask ourselves, “Would the NCAA approve of such a gift?” To learn the answer, we turn to the NCAA Rules and Regulations when Andrew began matriculating at Duke in 2005. As shown below, Chapter 13 prohibits the University from offering and the prospective student from accepting any gift or promise of a future gift not specifically approved by the regulations. In the case of an ambiguity, the student may accept a benefit “if it is determined that the same benefit is generally available to the institution’s prospective students … or to particular segment of the student body (e.g., foreign students, minority students) determined on a basis unrelated to athletics ability.” Chapter 16 places the same restriction on current student athletes.
Nowhere does the NCAA manual specifically permit free lifetime access to state of the art golf training facilities. So we must apply the general availability test. Applying this rationale to Andrew’s case, we quickly see that a promise of lifetime access to Duke’s golf facilities violates the rules; thereby, making Mr. Giuliani ineligible to participate on Duke’s NCAA Division I golf team. Not only did Duke not offer the same access to all its students, Andrew specifically claims the benefit based on his membership on an athletic team. While, one could argue that Andrew could have reinstated his eligibility by simply nullifying the contract. Apparently, he never exercised that option when filing his annual Student Athlete Statements (Form 05-3a). The Student Athlete Statement, implemented in 2005, requires all NCAA athletes to annually certify that they understand the NCAA rules, and have not violated any of them. Further, a student’s failure to identify potential violations for prompt resolution would independently constitute an ethical violation subjecting the student to disqualification under Bylaw 14.01.3.3. We’ve now reached the dilemma. Since, by his own admission, Andrew was ineligible for the golf team, does he have the right to challenge the process used to expel him from the team? If you stop and think of all the ramifications, you can easily see why Magistrate Judge Dixon simply said, “No letter-of-intent - no contract!” To conclude that Coach Myers made an enforceable oral contract with Andrew Giuliani that clearly violated NCAA regulations is simply not plausible. 
Edited by sdsgo, Jun 25 2009, 01:16 PM.
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