Back in February, a federal court in Connecticut dismissed a lawsuit brought by three former wrestlers who contended, among other things, that they were improperly classified as independent contractors.
The case garnered national attention (see, for example, this post by Zach Lowe at The American Lawyer) for a variety of reasons, including the disclosure of the wrestlers contracts. (If you’d like to see the details on the contract, you can view them here.)
But after that, two of the three wrestlers (Scott Levy and Christopher Klucsarits) filed a motion to amend the judgment or otherwise set it aside to allow them an replead (or refile) their claims. Notably, one of the wrestlers — Michael Sanders — did not join in this motion.
On July 31, 2009, the District Court denied the wrestlers’ motions, finding that even if it allowed the amendments at this late date, such amendments would be "futile". In other words, even if the court allowed the amendment, the wrestlers would STILL lose on the merits. You can download the decision here.
The wrestlers contended that they could still make a claim under the federal law governing benefit plans. But the court said that even that claim would fail.
In the proposed amended complaint, Plaintiffs assert that “they are participants in
defendant [World Wrestling Entertainment, Inc.’s] ERISA plans and are entitled to the full
benefits of such plans.” However, this claim relies on the reiteration of Plaintiffs’ argument espoused in the first complaint. Plaintiffs assert that they were unaware of Defendants’ intention to treat them as independent contractors and that an employer-employee relationship developed between themselves and Defendants.
However, this Court has already rejected Plaintiffs’ argument that their relationship with defendants evolved to employer/employee status. The Booking Contracts that outline the terms and conditions of the relationship between WWE and each wrestler specifically stipulate that Plaintiffs are independent contractors. Furthermore, Plaintiffs cite no authority to support their employer-employee claim and did not show that the Booking Contracts were invalid. Thus, an amendment to assert an ERISA claim premised upon an employer-employee relationship between Plaintiffs and Defendants would be futile as it fails to state a cognizable cause of action.
The wrestlers now have the option of appealing the matter to the Second Circuit Court of Appeals. But given how the district court disposed of the matter, the results of such an appeal may be as preordained as a professional wrestling match.