Marquette Sports Law Review Volume 16 Article 5 Issue 2 Spring Affirmative Injunctions in Athletic Employment Contracts: Rethinking the Place of the Lumley Rule in American Sports Law Geoffrey Christopher Rapp Follow this and additional works at: http://scholarship.law.marquette.edu/sportslaw Part of the Entertainment and Sports Law Commons Repository Citation Geoffrey Christopher Rapp, Affirmative Injunctions in Athletic Employment Contracts: Rethinking the Place of the Lumley Rule in American Sports Law, 16 Marq. Sports L. Rev. 261 (2006) Available at: http://scholarship.law.marquette.edu/sportslaw/vol16/iss2/5 This Article is brought to you for free and open access by the Journals at Marquette Law Scholarly Commons. For more information, please contact
[email protected]. AFFIRMATIVE INJUNCTIONS IN ATHLETIC EMPLOYMENT CONTRACTS: RETHINKING THE PLACE OF THE LUMLEY RULE IN AMERICAN SPORTS LAW GEOFFREY CHRISTOPHER RAPP* In the summer of 2005, American football fans were once again confronted with the ugly specter of a superstar athlete holding out for renegotiation of a contract. Terrell Owens, the Philadelphia Eagles wide receiver who helped his team dominate the National Football Conference (NFC) last year after being traded from San Francisco, publicly threatened to refuse to play unless the Eagles renegotiated his seven-year, $49 million contract, which he had been more than willing to sign last year.' In the end, at least for the moment, it seems that "T.O." and the Eagles reached an agreement allowing him to return to camp.2 Other players, however, maintained their holdouts long into the hot days of August, 3 denying their teams their presence during important training evolutions and preseason games.