CONTRACT-LITTLE LEAGUE WORLD SERIES

Needville Little League v. Little League Baseball, Pa. Civil No. 21-00801 (C.P. Lycoming January 4, 2022) (Linhardt, J.)  Plaintiffs claimed breach of contract resulting in plaintiff’s wrongful exclusion from the Little League World Series and causing them damages.  The court found that plaintiffs should be permitted to amend because they did not attach sufficient materials to their complaint to show what the contract was that was breached.  The Court finds that Plaintiffs have pied the existence of a contract: the Charter as amended by the COVID-19 protocols. Plaintiffs essentially alleged that the Charter is an agreement between the parties, pursuant to which Plaintiffs paid registration fees and agreed to abide by Defendant’s rules and regulations, and Defendant agreed to conduct a nationwide tournament in accordance to certain procedures.  The Court will not grant a demurrer on the basis of failure to plead the existence of a contract or the contention that the COVID-19 protocols were not part of a contract between the parties as a matter of law. Defendant has pointed to a provision of the COVID-19 protocols reproduced in Plaintiffs’ Complaint that states Defendant “will work efficiently to communicate with the appropriate family members, team contacts, and state health officials, to initiate all appropriate quarantine, isolation, and contact tracing procedures.” Defendant argues that this provision reflects broad discretion to amend its response to the COVID-19 pandemic given the uncertainty and risk of running tournaments in the summer of 2021. Ultimately, while the Complaint lists in detail many of the acts of Defendant that Plaintiffs consider wrongful, it does not state with specificity which provisions of the contract Plaintiffs contend Defendant breached, in what manner those breaches occurred, or which of Defendant’s actions breached the implied covenant of good faith and fair dealing. The failure to attach the contract hinders the Court’s analysis of these questions.