Dallas Cowboys Football Club v. Harris
348 S.W.2d 37 (1961)
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Rule of Law:
In a personal services contract, an employee's skills are considered 'special, exceptional and unique' sufficient to warrant an injunction against breach if the services require such special knowledge and ability that they could not be easily obtained from others, even if the employee is not literally irreplaceable.
Facts:
- In June 1958, James B. Harris signed a one-year contract to play football for the Los Angeles Rams Football Club, which included an option for the Rams to renew it for an additional year.
- The contract stated that Harris possessed 'special, exceptional and unique knowledge, skill and ability' as a football player.
- The contract also contained a 'tolling' provision, stating that if Harris retired from professional football, the contract term would be paused until his return.
- On April 15, 1959, the Los Angeles Rams exercised their option to renew Harris's contract for the following season.
- Harris did not play professional football during the 1959-1960 season, instead enrolling as a student and working as an assistant football coach at the University of Oklahoma.
- In April 1960, Harris signed a new contract to play football for the Dallas Texans Football Club.
- On July 22, 1960, the Los Angeles Rams assigned their contract with Harris to the Dallas Cowboys Football Club, Inc.
Procedural Posture:
- Dallas Cowboys Football Club, Inc. (the Club) sued James B. Harris in trial court seeking an injunction to prevent him from playing for any team other than the Club.
- The trial court granted the Club a temporary injunction. Harris, as appellant, appealed this temporary order.
- The case proceeded to a trial on the merits for a permanent injunction.
- A jury, in response to Special Issue No. 1, found that Harris did not possess 'exceptional and unique knowledge, skill and ability as a football player.'
- Based on the jury's verdict, the trial court rendered a final judgment denying the Club a permanent injunction.
- The Club, as appellant, appealed the final judgment on the merits to the Court of Civil Appeals.
- The Court of Civil Appeals consolidated Harris's appeal from the temporary injunction with the Club's appeal from the final judgment.
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Issue:
Is a professional football player's service considered to have 'special, exceptional and unique knowledge, skill and ability' sufficient to warrant an injunction against breach of contract, when his services cannot be easily replaced, even if he is not literally the 'only' or 'best' player of his kind?
Opinions:
Majority - Dixon, Chief Justice
Yes, a player's service is unique if it cannot be easily replaced. The court held that the jury's finding that Harris lacked unique skill was against the great weight and preponderance of the evidence, as it was based on an improperly narrow and limited definition of the word 'unique'. The proper legal standard, adopted from precedent, is not whether the employee is impossible to replace, but whether the service requires such special skill and ability that a substitute 'could not easily be obtained from others.' All testimony, including from Harris's new team manager and Harris himself (initially), indicated he was an above-average player whose services were not readily available to the Club. Therefore, the trial court erred in not granting a new trial. The court also rejected Harris's claims that the contract option was invalidly exercised or had expired, finding the option was properly exercised and the contract term was tolled during his year away from professional football.
Analysis:
This case is significant for clarifying the legal standard for 'unique services' required to obtain an injunction in personal services contracts, particularly in professional sports. By rejecting a literal, 'irreplaceable' definition in favor of a more practical 'not easily obtained' standard, the decision strengthens the enforceability of negative covenants in athlete contracts. It establishes that even if a player is not the absolute best, their high level of skill can be deemed unique if replacements of a similar caliber are not readily available. This precedent gives employers, like sports franchises, a more powerful tool to prevent key employees from breaching their contracts to work for competitors.
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