Hunt v. Zuffa, LLC

Procedural entryThis page is a short order in Hunt v. Zuffa, LLC. Read the opinion of the Court — 361 F. Supp. 3d 992
District Court, D. Nevada·Decided November 22, 2019·No. 2:17-cv-00085·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Mark Hunt, Case No.: 2:17-cv-00085-JAD-VCF 4 Plaintiff Order Granting Zuffa’s Motions for 5 v. Summary Judgment and to Seal 6 Zuffa, LLC, et al., [ECF Nos.154, 155, 156] 7 Defendants 8 Plaintiff Mark Hunt filed this lawsuit against Zuffa, LLC dba Ultimate Fighting 9 Championship (UFC), its president Dana White, and mixed martial arts (MMA) fighter Brock 10 Lesnar, allegingthat UFC manipulated its own drug-testing requirements to allow select fighters 11 to use performance-enhancing drugs. Hunt, who professes to be a drug-free fighter,claims that 12 he lost at least two bouts against drug-enhanced competitors, including Lesnar,damaging his 13 brand as an MMA fighter, stunting several of his related income streams, andphysically injuring 14 him. 15 Motions to dismiss havewhittled Hunt’s casedown toa singlecause of actionagainst 16 UFC for breachof the implied covenant of good faith and fair dealing.1 UFC now moves for 17 summary judgment on that claim and to seal certain exhibits to its motion.2 Because Hunt’s 18 contract with UFC precludes the consequential damages that Hunt seeks with his breach-of- 19 implied-covenant claim and he has shown no genuine issue of fact as tothat essential element, I 20 grant UFC’s motion for summary judgment. I also grant UFC’s motion to seal because 21 compelling reasons exist to seal the information. 22 1 ECF Nos. 63, 65, 152. 23 2 ECF Nos. 154 (redacted motion for summary judgment), 155 (sealed motion for summary judgment), 156 (motion to seal). 1 Discussion3 2 I. Motion for summary judgment [ECF Nos. 154, 155] 3 A. Standard 4 Summary judgment is appropriate when the pleadings and admissible evidence “show 5 there is no genuine issue as to any material fact and that the movant is entitled to judgment as a

6 matter of law.”4 “The plain language of Rule 56(c) mandates the entry of summary judgment, 7 after adequate time for discovery and upon motion, against a party who fails to make a showing 8 sufficient to establish the existence of an element essential to that party’s case, and on which that 9 party will bear the burden of proof at trial.”5 When that happens, “there can be ‘no genuine issue 10 as to any material fact,’since a complete failure of proof concerning an essential element of the 11 nonmoving party’s case necessarily renders all other facts immaterial.”6 In evaluating a motion 12 for summary judgment, the court views all facts and draws all inferences in the light most 13 favorable to the nonmoving party.7 If reasonable minds could differ on material facts, summary 14 judgment is inappropriate because its purpose is to avoid unnecessary trials when the facts are

15 undisputed, and the case must then proceed to the trier of fact.8 16 17 18 19 3 The parties are familiar with the facts of this case and I will not repeat them in detail here. I incorporateherein the facts detailed in my most recent dismissal order. See ECF No. 152. 20 4 See Celotex Corp. v. Catrett, 477 U.S. 317, 330 (1986) (citing Fed. R. Civ. P.56(c)). 21 5 Id. at 322. 22 6 Id. at 322–23. 7 Kaiser Cement Corp. v. Fishbach & Moore, Inc., 793 F.2d 1100, 1103 (9th Cir. 1986). 23 8 Warren v. City of Carlsbad, 58 F.3d 439, 441 (9th Cir. 1995); see also Nw. Motorcycle Ass’nv. U.S. Dep’t of Agric., 18 F.3d 1468, 1471 (9th Cir. 1994). 1 B. Damages 2 UFC argues that Hunt cannot demonstrate the existence of any recoverable damages 3 because consequential damages are barred under UFC’s Promotional and Ancillary Rights 4 Agreement (PARA) with Hunt.9 Hunt responds that there is a genuine dispute of fact as to 5 whether UFC’s removal of Hunt from a November 19, 2017,bout breached the implied

6 covenant.10 And he claims that he suffereddamages in the form of wastedtraining-camp 7 expenses and delayed payment for his fourth fight under the PARA.11 UFC replies that the 8 training-camp expenses are non-recoverable consequential damages and that Hunt provides no 9 evidence of damages from delayed payment for the fourth bout.12 10 “The party seeking damages has the burden of proving the fact that he was damaged and 11 the amount thereof.”13 “Generally, the remedy for a breach of the implied covenants of good 12 faith and fair dealing is limited to contractual remedies.”14 These include consequential 13 damages, which “should be such as may fairly and reasonably be considered as arising naturally, 14

15 16 9 ECF No. 155 at 5. 17 10 ECF No. 159 at 3–5. As a preliminary matter, Local Rule 56-1 requires a party opposing 18 summary judgment to include “a concise statement setting forth each fact material to the disposition of the motion that the party claims is or is not genuinely in issue, citing the particular 19 portions of any pleading, affidavit, deposition, interrogatory, answer, admission, or other evidence on which the party relies.” D. Nev. L. R. 56-1. Although Hunt fails to include such a 20 statement in his opposition,I decide the motion on its merits because UFC is entitled to judgment as a matter of law. 21 11 Id. 22 12 ECF No. 168 at 5–8. 13 Gibellini v. Klindt, 885 P.2d 540, 543 (Nev. 1994). 23 14 Shaw v. CitiMortgage, Inc., 201 F. Supp. 3d 1222, 1251 (D. Nev. 2016) (citing Mundy v. Household Fin. Corp., 885 F.2d 542, 544 (9th Cir.1989)). 1 or were reasonably contemplated by both parties at the time they made the contract.”15 Nevada 2 Revised Statutes § 104.2719(3) provides, however, that “consequential damages may be limited 3 or excluded unless the limitation or exclusion is unconscionable.”16 4 UFC shows an absence of evidence ofdamages from the breach of the implied covenant 5 by pointing to the PARA, which provided fixed compensation for a certain number of bouts and

6 bars consequential damages,17 satisfyingits initial burden on summary judgment.18 Hunt 7 responds that his removal from the November 19, 2017,bout caused him damages in the form of 8 training-camp expenses and delayed payment for his fourth fight under the PARA. Hunt offers 9 no evidence of damages resulting from the delayed payment. As fortraining-camp expenses, 10 Hunt declares that they are “customary,reasonable and foreseeable in the industry of 11 professional mixed martial arts.”19 Because the training-camp expenses were thus reasonably 12 foreseeably when Hunt and UFC entered into the PARA, they constitute consequential damages 13 and are expressly barred under the PARA. Hunt has thus failed to showtoa genuine dispute of 14 fact as to damages.

15 Hunt alsoargues that the provision barringconsequential damages is unconscionable, but 16 he offers no analysis to support it. In any event, Nevada law specifically permits such 17 18 19 15 Century Sur. Co. v. Andrew, 432 P.3d 180, 183 (Nev. 2018) (defining contract damages) (quotation omitted). 20 16 Nev. Rev. Stat. § 104.2719(3). 21 17 ECF No. 155-2 at 6–7, 12.

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