by George Benaur and Ben Rozenshteyn
The recent case of Christophe Jean v. Leonard Francois et al., 19-002954 (Fla. 17th Cir. Ct. 2019), which involves the tennis superstar Naomi Osaka, concerns the dynamic between coaches and athletes, in this case, tennis players and their coaches. Given my affinity for tennis and contract law, I decided to write about it, since it shows the mistakes that can be made with a poorly written contract. As is often the case, without adequate and competent legal representation, the two sides, especially when trying to save costs early on in a young career, can bind themselves through a contract which is subpar at best, or entirely inoperable at worst.
Naomi Osaka, a famous tennis player now, recently won a dismissal of suit over a former coach suing her for 20% of everything she’s worth. In an order filed on Friday, September 13, Broward County Circuit Court Judge David A. Haimes said it was “obvious that tennis trainer Christophe Jean’s suit should be dismissed.”
The contract at issue was allegedly drafted and signed in 2012, when Osaka’s father, Leonard Francois, asked her coach, Jean, to keep training Osaka even though he was unable to pay. Some coaches reportedly agreed to instruct the driven and talented Osaka girls for free while others, like Jean, tried to make arrangements that would defer payment.
One of the Osaka sisters, now 21, is ranked as the top tennis player in the world by the Women’s Tennis Association, taking more than $10 million in prize money thus far during her short career. Osaka was represented in the lawsuit by Quinn Emanuel Urquhart & Sullivan LLP, a large international law firm that was able to win a dismissal of the former coach’s complaint. The attack on the contract involved:
i. The contract entitled the coach to 20% of all of Osaka’s tennis-related earnings for an “indefinite” period, which according to the Judge, was impossibly vague.
ii. Florida’s Child Performer and Athlete Protection Act states that in order to sign such a contract on behalf of a minor and make it valid, the deal needs to be submitted for court approval first. The coach never did that, and therefore the deal was void from the outset.
iii. Contracts with minors are voidable and the minor has a legal right to disavow a contract because of minority. Mari and Naomi Osaka were 14 and 15 years old at the time of the alleged contract, and they have disavowed the contract.
Of course, in every case, the devil is in the details and we do not know all the facts and circumstances here. For example, it is not entirely clear whether the case could have succeeded under a different set of facts. In certain circumstances, quasi-contractual theories, such as “unjust enrichment” may be successful to recover, even if the contractual claim fails. But what this case demonstrates with clarity is the potential pitfalls of entering into badly written and poorly negotiated contracts which lack some basic material terms. For these reasons, it is imperative that the clients recognize that they should invest some money and resources into having a legal review of their contracts before entering into them. In this regard, we include below a link to the article that we wrote on the subject matter more than five years ago, which remains fully applicable today.