National Collegiate Athletic Ass'n v. American Basketball Ass'n

67 Pa. D. & C.2d 552, 1974 Pa. Dist. & Cnty. Dec. LEXIS 453
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedAugust 5, 1974
Docketno. 2145 of 1972
StatusPublished

This text of 67 Pa. D. & C.2d 552 (National Collegiate Athletic Ass'n v. American Basketball Ass'n) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Collegiate Athletic Ass'n v. American Basketball Ass'n, 67 Pa. D. & C.2d 552, 1974 Pa. Dist. & Cnty. Dec. LEXIS 453 (Pa. Super. Ct. 1974).

Opinion

BLOOM, J.,

The matter before this court arises from a complaint in equity filed by plaintiff, National Collegiate Athletic Association (hereinafter NCAA) against the American Basketball Association (hereinafter ABA) and Howard E. Porter.

The complaint in equity seeks certain injunctive relief against defendant ABA only. It seeks damages from both defendants, ABA and Porter, for certain alleged tortious conduct.

Defendant ABA has filed an answer denying the allegations set forth in the complaint but the ABA has not filed any prehminary objections.

Defendant Porter has filed prehminary objections to said complaint alleging:

(1) That this court has no jurisdiction over the person of defendant Porter;

(2) That the complaint in equity against Porter does not set forth a cause of action upon which injunctive relief can be granted;

(3) That the complaint does not set forth a cause of action for damages;

(4) That the complaint does not join an indispensable party.

[554]*554This opinion is written in disposition of defendant Porter’s preliminary objections.

The complaint alleges that the NCAA is an unincorporated association which regulates intercollegiate athletics among its members. It also sponsors or conducts certain tournaments or championship events, including basketball tournaments. Under NCAA rules, participation in intercollegiate athletic events by members of the NCAA is limited to student athletes who meet the eligibility standards for amateurism as established by the NCAA. Pursuant to said rules, a student athlete is ineligible to participate in intercollegiate athletic events if “he takes, has taken, or has accepted the promise of pay, in any form, for participation in athletics; or he has entered into an agreement or any kind to compete in professional athletics, or to negotiate a professional contract; or he has, directly or indirectly, used his athletic skill for pay in any form, including the promise of pay to be received following the completion of his intercollegiate career; or he has ever signed a contract or commitment of any kind to play professional athletics, regardless of its legal enforceability or the consideration, if any, received; or he receives, or has ever received, directly or indirectly, a salary, reimbursement of expenses, or any other form of financial assistance from a professional sports organization for any purpose whatsoever; or he agrees, or has ever agreed, to be represented by an agent or an organization in the marketing of his athletic ability or reputation.”

During the 1970-71 collegiate basketball season, defendant Porter participated on behalf of Villanova University in intercollegiate basketball games and tournaments sponsored by NCAA. It is alleged that on or about December 16,1970, Porter entered into a contract with ABA, a professional basketball organization [555]*555whereby the ABA paid Porter the sum of $15,000 for. signing the agreement. In general, the said agreement allegedly obligated Porter to play professional basketball for ABA in consideration for further sums of money. Subsequent to the alleged execution of said agreement, Porter participated in NCAA sponsored games and tournaments contrary to the rules and regulations of NCAA.

The complaint further alleges that on January 24, 1971, and February 4, 1971, Porter executed written statements that he had not orally or otherwise entered any agreement which would render him ineligible to participate in NCAA sponsored events. Plaintiff alleges that Porter had entered such an agreement and that Porter “willfully, knowingly, maliciously and falsely” represented that he had not done so and that said representations were made “with intent to deceive and defraud” the NCAA and its reputation.

As to ABA, the complaint alleges that it “enticed, induced and purposefully caused” Porter to enter the aforesaid agreement and that ABA “did so covertly, secretively and without disclosing to the NCAA.” The complaint further alleges that ABA “with intent to deceive, mislead and defraud the NCAA” willfully and falsely represented that Porter had not signed a contract nor agreed to play professional basketball for ABA.

Relying upon the alleged representations made by Porter and ABA, plaintiff permitted Porter to participate in NCAA sponsored games and tournaments. As a result of the aforesaid representations, NCAA incurred certain money damages, including compensation for damage to the reputation of NCAA in sponsoring wholly amateur athletic events.

In count two of the complaint, plaintiff alleges that ABA has falsely represented on other occasions that [556]*556certain student athletes had not executed similar agreements to play professional basketball and that ABA “will continue to induce, entice and purposefully cause” other student athletes to enter professional contracts, without disclosing same to NCAA. It is further alleged that ABA will not disclose such other signings with the “intent to deceive, defraud and mislead'the NCAA” to the damage and injury of the NCAA and its members. As a result, NCAA prays that the ABA be enjoined from such conduct and that ABA be required to disclose the name of each and every athlete “with collegiate eligibility remaining who has heretofore entered into or hereafter, directly or indirectly, expressly or impliedly, enters into any contract, commitment, declaration of intent or agreement, written or oral, to play professional basketball in or for the ABA,” within 24 hours after same.

We now turn to a consideration of defendant Porter’s preliminary objections, the first of which is that this court has no jurisdiction as to the person of defendant.

The complaint alleges that on February 4, 1971, Porter appeared before a notary public in Radnor Township, Delaware County, Pa., and executed under oath a statement that he was an eligible athlete under NCAA rules and that he had not, verbally or in writing, entered a contract or a statement of intent to play professional basketball with any organization. He further set forth that he had not been paid or received a promise of payment from any professional organization and that he had not been solicited to sign a contract or statement of intent to play professional basketball.

In addition, Porter signed a similar statement for Villanova University and it also alleged that he played basketball for Villanova after entering a professional [557]*557contract with the ABA. Subsequent thereto, Porter played basketball for Villanova both within and outside of Pennsylvania.

The applicable statutes in effect at the time of service upon Porter provide:

“(A)ny nonresident of this Commonwealth who . . . shall have committed a tortious act within this Commonwealth, or any such individual who at the time of the commission of the tortious act within the Commonwealth was a resident of this Commonwealth . . . shall be conslusively presumed to have designated and constituted the Secretary of the Commonwealth of Pennsylvania as his agent for the service of process in any civil action or proceedings instituted in the courts of the Commonwealth of Pennsylvania against such individual”: 12 PS §341.
“(A)ny nonresident . . . who, acting outside of the Commonwealth . . .

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Cite This Page — Counsel Stack

Bluebook (online)
67 Pa. D. & C.2d 552, 1974 Pa. Dist. & Cnty. Dec. LEXIS 453, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-collegiate-athletic-assn-v-american-basketball-assn-pactcompldelawa-1974.