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Benton ex rel. Child v. Little League Baseball, Inc.
James A. Karamanis, Kenneth A. Nazarian, and Emily A. Herbick, of Barney & Karamanis, LLP, of Chicago, for appellants.
Scott T. Schutte, Tedd M. Warden, and Tyler Zmick, of Morgan, Lewis & Bockius LLP, of Chicago, for appellee Little League Baseball, Inc.
Brian A. Sher and Demetria L. Hamilton, of Bryan Cave Leighton Paisner LLP, of Chicago, and Nathan E. Siegel, of Davis Wright Tremaine LLP, of Washington, D.C., for appellees ESPN, Inc., and Stephen A. Smith.
Melinda S. Kollross and Paul V. Esposito, of Clausen Miller P.C., of Chicago, for appellees Jackie Robinson West Little League, Inc., Bill Haley, and Annie Haley.
No brief filed for other appellees.
¶ 1 In August 2014, Jackie Robinson West, an all African-American baseball team from the south side of Chicago, won the United States Little League World Series (World Series) title. This event aired nationally on ESPN to much acclaim, causing these 10-, 11-, and 12-year-old ‘‘South Siders’’ to become national media darlings before a tragic confluence of events led to the players being stripped of their title some six months later in February 2015, amid allegations of residency rule violations.
¶ 2 This appeal arises out of a lawsuit filed by the Jackie Robinson West parents/guardians, individually and on behalf of their 13 minor children, against Little League Baseball, Inc. (Little League), the team's corporate entity Jackie Robinson West Little League, Inc. (Jackie Robinson West, Inc.1 ), team president Annie Haley and team treasurer Bill Haley (collectively, the Haleys), as well as ESPN, Inc., and its employee Stephen A. Smith (ESPN/Smith), among others. Several counts were also individually filed by team manager and head coach Darold Butler (Coach Butler), who is also a parent. The suit included claims for breach of implied contract, promissory estoppel, defamation, intentional and negligent infliction of emotional distress, false light, and civil conspiracy. The Jackie Robinson West players also sought to be reinstated as champions. As to the second-amended complaint, the trial court dismissed with prejudice all counts filed by the parents on their own behalf and several counts filed on the children's behalf. The court, however, denied motions to dismiss claims for breach of implied contract (count I) and promissory estoppel (count II), and intentional infliction of emotional distress (counts VI and VIII), which were filed on behalf the children.
¶ 3 This interlocutory appeal followed with Little League, Jackie Robinson West, Inc./the Haleys, and ESPN/Smith filing briefs in response. For the reasons delineated below, we affirm the trial court's judgment dismissing the various counts but hold that reinstatement of the championship title remains a viable remedy as to counts I and II.
¶ 5 The following facts are gleaned from the pleadings, motions, exhibits, and orders that precede this appeal. Little League is a not-for-profit corporation providing international youth baseball and softball programs for players ages 4 to 18. To participate, players of the correct age must live within or attend school within certain geographical boundaries designated annually by each local league. Jackie Robinson West, Inc., with players emanating from the south side of Chicago, was just one of these locally chartered teams and had gained approval from Little League in late April 2014. Although such teams form annually, the Jackie Robinson West team is a storied South Side league, dating as far back as the 1980s. In support of the 2014 charter, Jackie Robinson West, Inc., submitted the requisite boundary map to Illinois Little League District 4 (District 4), since each local league was to determine its own boundaries. Plaintiffs alleged in their second-amended complaint that District 4 then emailed the map to the next organizational tier, Little League's central regional office in Indianapolis, Indiana. In addition to the Jackie Robinson West team, District 4 supervised three other Chicago-area little league teams.
¶ 6 The Jackie Robinson West team began its regular baseball season in May 2014 and concluded a month later. Only certain players then participated in the post-season tournaments. With help from Coach Butler, Jackie Robinson West created a formidable team of 13 all-star players. Subject to great fanfare and media coverage, this team won regional and state championships, and in August 2014, the World Series. The team then competed internationally but ultimately lost to a South Korean team. ESPN televised certain tournaments, including the World Series. This was reportedly the most watched little league series ever on that network.
¶ 7 Up to this point, there was no question that Jackie Robinson West was a legitimate team under Little League's guidelines, having advanced and won the World Series fair and square. That view, however, would soon become cloudy. In September 2014, Chris Janes, the vice president of a rival suburban league, approached Little League and protested the Jackie Robinson West players' eligibility based on their residency.2
¶ 8 To understand this protest, and by way of background, it's worth noting that before participating in regional tournaments in July, Coach Butler created a binder containing the Jackie Robinson West children's birth certificates, residency documents, and a boundary map dated May 1, 2014.3 This binder served as supporting documentation for the requisite "Tournament Team Eligibility Affidavit," meant to ensure that the 13 players were qualified under Little League rules to play for Jackie Robinson West. The affidavit lists the players by name, identifies their residences/schools, and states that the residences/schools listed for each player had to be inside the boundaries defined by the submitted map. Significantly, this photocopied tournament map was the same as that attached to the team's original charter and signed by team president Haley and Little League District Administrator Michael Kelley. This simple boundary map provided a black-line graphic of the north, south, east, and west borders and appeared to plot the players' corresponding residences/schools within the boundaries.
¶ 9 The parties do not dispute that the addresses listed in the affidavit under each of the players' names were correct. Little League, however, maintains "the actual addresses were outside the eligible borders for players." In other words, not all of the 13 players resided within the team's identified boundaries. It is this detail that allegedly fell through the cracks and rendered the Jackie Robinson West team reportedly ineligible to compete.
¶ 10 In spite of this discrepancy, the affidavit contains various signatures by officials from Jackie Robinson West, Inc. and Little League, guaranteeing the accuracy of the information contained therein. For example, Coach Butler, President Haley, and District Administrator Kelley signed the affidavit in July 2014. Little League Regional Tournament Director Nina Johnson also certified the affidavit as being accurate in July 2014.
¶ 11 Plaintiffs presented this eligibility affidavit for review to the "Tournament Director" at each of their post-season tournaments, including at the World Series.4 Additionally, the affidavit stated that if the tournament committee, which league guidelines vested with sole authority over tournaments, deemed any player ineligible due to residency problems, the team could forfeit the tournament game and be removed from play.5 It could also result in removal of personnel from league activities.
¶ 12 It apparently was this residency rule that Janes focused on in his protest. In response, Little League "conducted an investigation and determined the Tournament Affidavit addresses were correct." Plaintiffs, however, maintain that as of September and October, other Little League officials and the team's corporate personnel knew something was up. Plaintiffs maintain that Regional Tournament Director Johnson and another Little League...
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