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Case Outlines
Los Angeles Rams Football Club V. Cannon (Page 76 in textbook)

Background
Billy Cannon is a highly touted draft prospect coming off a successful college career at LSU, which included a Heisman Trophy win. The Los Angeles Rams of the NFL were the first in signing him to a $50,000 contract. However, Cannon subsequently signed a $100,000 contract with the AFL’s Houston Oilers. The Rams sued Cannon in an effort to prevent him from performing any football activity for any organization other than their own.

The Facts Of The Case
The defendant did sign a contract with the Los Angeles Rams covering the span of the 1960-1962 seasons. He then received two checks for $10,000 and $500. Not long after, the defendant signed another contract with the Houston Oilers for $100,000, subsequently contacting the Rams to tender his resignation and return the uncashed and unendorsed checks he previously received.

Legal Issue At Hand
Does the language in the first contract with the Rams that states “This agreement shall become valid and binding upon each party hereto only when, and if it shall be approved by the Commissioner”, absolve Cannon of any wrong doing? Even though both parties (The Rams and Cannon) signed the contract, does the absence of the Commissioner’s endorsement make it non-binding?

Appellees Argument
The defendant signed a contract with the appellee and the absence of the Commissioner’s contract is deemed by them to be “an unimportant ministerial act concerning only the League and the Club”.

Defendant’s Argument
The contract was not signed by the Commissioner, and therefore insists that the signature of the Commissioner is “absolutely essential to the formation of the contract”.

Court’s Ruling
The court ultimately ruled with the defendant. The main reason was the language of the contract. The terms and conditions were too specific and definite to rule any other way but in the favor of Billy Cannon, as the absence of the Commissioner’s contract was

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