Jackie Robinson West Lawsuit 1/11/16

8/20/2019 Jackie Robinson West Lawsuit 1/11/16

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ELECTRONICALLY FILED

2 11/2016 8:30AM

2016-L-001428

CALENDAR:H

PAGE 1 of43

CIRCUIT COURT OF

IN THE

CIRCUIT

COURT OF COOK

COUNTY

ILLINBBIS COUNTY;, ILLINOIS

, LAW

DIVbiON

COUNTY DEPARTMENT LAW

DIVISIQN CLERK DOROTHY BROW

DEVONA D. BENTON and FRANK JACKSON, )

individually, and on behalf of their minor child, J B.; )

ROBERTS. BUFFORD, JR., Individually, and on behalf )

of their minor child, C. B.; DAROLD BUTLER, SR. and )

DO NIT A BRUCE, individually, and on behalf of their )

minor child, D.B.; VENISA BEASLEY -GREEN and )

CHRISTOPHER GREEN, individually, and on behalf of )

their minor child, B.G.; CARLTON A. HONDRAS,

II

and )

SHEREE HONDRAS, individually, and on behalf

of

)

their minor child, C.H.; JERRY F. HOUSTON and )

MYRTLE HOUSTON, individually, and on behalf

of

)

their minor child, J.H.; EDWARD HOWARD III, and )

CALANDRA HOWARD, individually, and on behalf

of

)

their minor child, E H.; LINDA SNEED HARRIS, )

individually, and

on

behalf

of

her minor child, M.J.; )

NEDRA JONES and ALVIN JONES, individually, and )

on behalf

of

their minor child, P.J.; TAMMY KING and )

EDDIE KING, SR., Individually, and on behalf of their )

minor child, E.K.; PRENTISS LUSTER and DARLENE )

LUSTER individually, and on behalfof their minor child, )

P.R.; SANJA E. NOBLE, Individually, and on behalf

of

)

her minor child, L.N.; and CLAUDIA HARVEY, )

individually, and on behalfof her minor child, D.R.; )

Plaintiffs,

v.

LITTLE LEAGUE BASEBALL, INCORPORA TED;

JACKIE ROBINSON WEST LITTLE LEAGUE, INC.,

an Illinois Not-for-Profit Corporation; BILL HALEY,

Individually, and as agent and/or employee

of JACKIE

ROBINSON WEST LITTLE LEAGUE, INC.; ANNIE

HALEY, Individually, and as agent and/or employee of

JACKIE ROBINSON WEST LITTLE LEAGUE, INC.;

EVERGREEN PARK ATHLETIC ASSOCIATION, an

Illinois Not-for-Profit Corporation; CHRIS JANES,

Individually, and as agent and/or employee

of

EVERGREEN

PARK

ATHLETIC ASSOCIATION;

ESPN, INC., a Delaware corporation; and STEPHEN A.

SMITH, Individually, and as agent of ESPN, INC.,

Defendants.

)

)

Case No.


2/26

COMPL INT T L W

NOW COME the Plaintiffs, DEVONA D. BENTON and

FRANK

JACKSON,

individually, and on

behalf

of their minor child, J B.;

ROBERTS.

BUFFORD, JR., Individually,

and on

behalfof

their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,


behalf of

their minor child, D.B.; VENISA BEASLEY -GREEN and

CHRISTOPHER GREEN, individually, and on

behalf

of their minor child, B.G.; CARLTON A

HONDRAS, II and SHEREE HONDRAS, individually, and on

behalf of

their minor child, C.H.;

JERRY F. HOUSTON and MYRTLE HOUSTON, individually, and on

behalf

of their minor

child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on

behalf

1

of

their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

Cl

LI l

~

00

1

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on

behalf of

their minor

><

( 1 ~ .

o :

child, P.J.; TAMMY KING and EDDIE KING, SR., Individually,

and

on

behalf

of their minor

U \ 0 N

LI.l

5 I child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on

behalf of

their

cX:;:::;CQ.;'

f 4 N

~

LI l minor child, P.R.; SANJA E. NOBLE, Individually, and on

behalf

of her minor child, L.N.; and

l

·LI.l

CLAUDIA HARVEY, individually, and

on

behalfof

her minor child, D.R.; (hereinafter

; collectively referred to as the

JRW

Parents ); by and through their attorneys, Barney

Karamanis, LLP, and complaining of Defendants, LITTLE LEAGUE BASEBALL,

INCORPORATED (hereinafter referred to as LITTLE LEAGUE ); JACKIE ROBINSON

WEST LITTLE LEAGUE, INC. (hereinafter referred to as JRWLL ); BILL HALEY,

Individually, and as agent and/or employee of JRWLL; ANNIE HALEY, Individually, and as

agent and/or employee

of

JRWLL; EVERGREEN

PARK

ATHLETIC ASSOCIATION

(hereinafter referred to as

EP

AA''); CHRIS JANES, Individually, and as agent and/or

2


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employee ofEPAA; ESPN INC.; and STEPHEN

A

SMITH Individually and as agent and/or

employee

ofESPN

INC.; state as follows:

P RTIES

1 At all times relevant hereto Plaintiffs the JRW Parents acting on behalf of

themselves and their minor children.

2 At all times relevant hereto. Defendant LITTLE LEAGUE was a Not-for-Profit

corporation federally-chartered under 36 U.S.C.

§

13501 and headquartered in Williamsport

Pennsy vania.

3

At all times relevant hereto Defendant JRWLL was an Illinois Not-for-Profit

corporation engaged in the operation of a Little League chartered baseball league on the South

Side

of

Chicago Cook County Illinois.

4

On

information and belief. and at all times relevant hereto Defendant Bill Haley

was a resident ofCook County Illinois.

5 At all times relevant hereto Defendant Bill Haley was an agent and/or employee

of

Defendant JRWLL.

6

At all times relevant hereto Defendant Bill Haley was acting within the course

and scope of his agency and/or employment with Defendant JRWLL.

7 On

information and belief and at all times relevant hereto Defendant Annie

Haley was a resident ofCook County Illinois.

8

At all times relevant hereto Defendant Annie Haley was an agent and/or

employee ofDefendant JRWLL.

9

At all times relevant hereto Defendant Annie Haley was acting within the

course and scope of her agency and/or employment with Defendant JRWLL.

3


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10 At all times relevant hereto, Defendant,

EP

AA, was an Illinois Not-For-Profit

corporation organized under the laws

o

the State

o

Illinois, engaged in the operation

o

a Little

League chartered baseball league in Evergreen Park, Cook County, Illinois.

11 On

information and belief, and at all times relevant hereto, Defendant, Chris

Janes, was a resident

o

Cook County, Illinois.

12 At all times relevant hereto, Defendant, Chris Janes, was an agent and/or

employee ofDefendant, EPAA.

13 At all times relevant hereto, Defendant, Chris Janes, was acting within the course

and scope

o

his agency and/or employment with Defendant, EPAA.

14 At all times relevant hereto, Defendant, ESPN, was a Delaware corporation, based

in Bristol, Connecticut, which owned and operated various sports broadcasting outlets, including

, cable channels, sports radio network, an accompanying website and other assets.

15 At all times relevant hereto, Defendant, Stephen A. Smith, was an agent and/or

employee o Defendant, ESPN, INC.

16

At all times relevant hereto, Defendant, Stephen

A

Smith, was acting within the

- course and scope o his agency and/or employment with Defendant, ESPN INC.

F CTS COMMON TO LL COUNTS

17 At all times relevant hereto, Defendant, Little League, organized and administered

local youth baseball and softball leagues throughout the U.S. and the rest

o

the world pursuant

to its official rules and regulations, with these official rules and regulations administered and

enforced by agents and/or employees in its Pennsylvania headquarters and District

Administrator s offices.


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18. At all times relevant hereto, Defendant, Little League, published its official rules

and regulations in a book entitled Little League® Rules and Regulations for Baseball Divisions-

2014 (hereinafter referred to as the Rule Book ). A copy o the relevant provisions o said Rule

Book are attached hereto as Exhibit A.

1

19. At all times relevant hereto, Defendant, Little League, issued charters

to

local

leagues on an annual basis with the requirement that the local league adhere scrupulously to all

rules and regulations established by Little League.

Ex.

A Administration,

p. 12.

20. At all times relevant hereto, Defendant, Little League, placed the responsibility o

revtewmg, granting, suspending and/or revoking the privileges and conditions

o

the local

league's charter and the authority to grant any written requests o a local charter to waive a

specific rule or regulation with its Charter Committee.

Ex.

A Charter Committee/Waivers

o

Rules and Regulations, p. 12.

21.

In

order to be eligible, under the rules o Defendant, Little League, a player must

qualify under the Little League's definition o residence printed in Section 2 o this book, must

be

the correct 'league age' for the division, and must have parental consent.

Ex. A

Player

Eligibility, p. 12.

22. According

to

the Rule Book, [ e ]ach local Little League determines

the

actual

geographic boundaries o the area from within which it shall select players and these

boundaries must be described in detail and shown on a map and dated when making application

for a Little League charter. Ex. A, Residence and School Attendance Player Eligibility

Requirements,

p. 16.

1

ue

to

its length Plaintiffs have not attached a copy of the Rule Book in its enti rety to this Complaint. However

a complete copy of this Rule Book will

be

made available for inspection

and/or

copying upon request

of

any party.

5


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23 Section 2

o

the Rule Book, further provides that in order to be eligible to play

with a particular league, only players who reside or the physical location o the school where

they attend classes is within the boundaries provided

to

and approved by Little League Baseball,

Incorporated. d

24 Section 2 then lists the supporting documents which would be acceptable to

determine the residence

o

a player's parent or legal guardian, which included, for example,

driver's license, utility bills and medical records.

25

Section 2

o

the Rule Book, further provides that [i]t is recommended that the

league require some proof

o

residence or school attendance with the league's boundaries at the

time the player registers. Id., p 17

26 The Rule Book further provides that [i]f a claim for residency or school

· attendance

is

challenged, the above materials must

be

submitted

to

Little League Baseball,

Incorporated, with an affidavit o residency or school attendance from the parent(s) or guardian.

27

At all times relevant hereto, Defendant, JRWLL, was within the geographic

boundaries

o

the Defendant, Little League's, District Administrator for Illinois District Four

(hereinafter referred

to

as Illinois District Four ).

28. Sometime prior to April 30, 2014, Defendant, Little League, issued a charter to

Defendant, JRWLL.

29. On or about April 30, 2014, Defendant, JRWLL, submitted its 2014 boundary

map (hereinafter referred to as the JRW Map ) to Illinois District Four n compliance with the

Little League's rules and regulations.

6


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30. Sometime thereafter, Illinois District Four emailed the JRW Map to the Little

League Central Region Headquarters in Indianapolis, and the Little League Central Region

confirmed that the JRW Map had been received.

31. n or about May

1

2014, the 2014 regular season for the Defendant, JRWLL,

began.

32. Defendant, JRWLL, played regular season games from May

1

2014, to June 30,

2014.

33. During this regular season, the League coaches, Plaintiff, Darold Butler, along

-

1

with the other coaches Houston and Little, selected a Tournament Team from the best players

.

in

the League.

34. According

to

the tournament rules o the Little League, [i]t shall be the league

president's responsibility

to

review and certify the birth records (league age) by viewing the

original birth record and residence (as defined by Little League Baseball, Incorporated) o all

players. When the league finally decides on the makeup o the team, names must be entered on

the league's Eligibility Affidavit. Once the District Administrator certifies the Eligibility

Affidavit, the tournament team will be required

to

have in its possession: (1) the Eligibility

Affidavit; (2) a map showing the actual boundaries

o

the league, with locations noted for the

residences o the parent or legal guardian (court appointed) or location o the school for every

participant named on the affidavit; (3) tournament verification form for each player (strongly

recommended); (4) three or more documents

to

determine residency o the parent(s) or legal

guardian (court appointed) or a document

to

support school attendance/enrollment for each

player named on the tournament affidavit; (5) waivers .. .. Ex.

A

Tournament Eligibility

Affidavit, p. T -4


8/26

35. Prior to every tournament level game the Eligibility Affidavit o each team must

e

certified by the District Administrator or his/her appointee and presented

to

the Tournament

Director.

36. The JRW Parents along with the rest

o

the Tournament Team parents then

submitted residency documents and birth certificates

to

Defendant Bill Haley.

37. At no time did Bill Haley inform the JRW Parents that their children were

ineligible

to play due to residency requirements.

38. At no time from April 2014 to August

o

2014 were any

o

the JRW Parents

aware o any residency issues that may have existed under rules o Defendant Little League.

39. From July 3 2014 to July 7 2014 the JRW League hosted the Illinois District

Four Tournament and advanced to the next tournament round.

40. From July 14 2014 to July 21 2014 the JRW Tournament Team participated in

the Illinois Section Three Tournament in Hegewisch Illinois which they won and again

· advanced.

41. The Illinois Section Three Tournament is where the JRW Tournament team

encountered Defendants Evergreen Park Athletic Association and Defendant Chris Janes.

42. From July 22 2014 to July 27 2014 th JRW Tournament Team attended and

won the Illinois State Championship in Manteno Illinois and earned a spot in th Great Lakes

Regional Tournament in Indianapolis.

43. At the Illinois State Championship volunteers working for the event were

charged with verifying the eligibility

o

the players on each participating team including the

JRW Tournament Team.

8


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44. From July 31, 2014, to August 9, 2014, the Great Lakes Regional Tournament

was held, which included participating teams from six states, and was televised by ESPN.

45. Plaintiff Darold Butler, as Coach o the JRW Tournament Team, submitted a

residency binder to Defendant Little League through its Central Region Tournament Director,

Scott Spillman (hereinafter referred

to

as Spillman ).

46. That residency binder included the JRW Map, the birth certificates o each

participating player, and the proo o residency documents for each JRW Tournament Team

player.

47. Defendant Little League was responsible for revtewmg and scrutinizing the

• residency documents with the boundary map, and then confirming the eligibility o each player

participating in the tournament.

48.

On information and belief, Little League was aware o the potential residency

issues o the children

o

the JRW Parents, but chose to ignore and/or deliberately conceal these

I

: facts in order to garner higher ratings, publicity, and money for Defendant Little League.

49. On or about August 9, 2014, the JRW Tournament Team defeated Indiana and

won the Great Lakes Regional Tournament; thereby advancing to the Little League World Series

Tournament.

50. From August

10

2014, to August 23, 2014, the JRW Tournament Team

continued to advance and succeeded in winning the United States Championship.

51. On or about August 24, 2014, the Jackie Robinson West Tournament Team was

defeated by South Korea in the International Championship game.


10/26

52. From April 30, 2014, to August 24, 2014,

no

complaints were lodged against the

JRW Tournament team for ineligibility, and no one informed any of the JRW Parents that there

was any problem with the residency

of

the players.

53. Instead of alerting the JRW Parents, the JRW Tournament Coach Darold Butler,

or the JRW Tournament Team members, Defendant Little League and Defendant JRWLL chose

to conceal and/or ignore any and all potential residency issues that existed during the

tournament.

54. In or around August of2014 Defendant JRWLL submitted its map and boundary

information to the Central Regional Assistant Tournament Director, Scott Spillman ( Spillman ).

55. In or around August

of

2014, Spillman expressly approved the information

submitted by Defendant JRWLL.

56. At all times relevant, Spillman was the assistant to the Tournament Director, Nina

Johnson.

57. At no time during the tournament was any protest or complaint raised against

JRWLL.

58.

n

September 9, 2014, Nina Johnson sent an email

to

JRW Coach Bill Haley,

indicating that there were ineligible players on the JRW Tournament Team.

59. In or around this time, Central Region Tournament Director Nina Johnson

contacted JRW owner Bill Haley about the JRW Map, but only after JRW had won the United

States Little League World Series.

60. In that September 9, 2014, email, Nina Johnson informed Defendant Bill Haley

that she had examined the map herself and told Coach Haley that eleven

of

the JRW players

lived within the proper boundaries and that two players lived outside of the boundaries.

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61. Nina Johnson and Pat Wilson expressly informed Bill Haley in September and

October 2014 that there were JRW players who lived outside the proper boundaries, however,

neither Defendant Little League, Defendants JRWLL, Bill Haley, nor Annie Haley take any

further steps to acknowledge the potential problem.

62. On or around November 6 2014, Defendant Little League organized a trip for the

JRW Tournament Team

to visit the White House and arranged for the JRW Team to attend the

Major League Baseball World Series in San Francisco.

63. Defendant Little League CEO Steve Keener and Rules Chairman Pat Wilson

accompanied the JRW Team to the White House and are included in the picture with President

Barack Obama.

64. After the visit with the President, Little League distributed the pictures from the

visit worldwide.

65. On information and belief, Defendant Little League deliberately capitalized on the

notoriety

o

the JRW Team and the JRW Parents

in

order

to

bolster its corporate image, gain

donations and otherwise profit from the unique appeal

o

the JRW Tournament Team.

66. On information and belief, Little League motivation

to

enhance its corporate

image

to

raise, among other things, the value o its television deal with ESPN.

67. At no time relevant did Defendant Little League contact JRW Coach Darold

Butler

to

determine what he knew or did not know regarding the childrens residency.

68. Defendant Little League did not contact any o the JRW Parents

to

investigate

further

as to

the residency issues.


12/26

69. Defendant Little League did not attempt to meet with the children, directly or

even through their parents,

to

explain

to

them that there were concerns regarding their respective

residency issues.

70. Defendant Little League did not meet with District Four Administrator Michael

Kelly to determine what was known about the boundary issues.

71 Defendant Little League did not expressly meet with anyone affiliated with JRW

and provide an explanation as

to

which rule or rules n the relevant rulebook were at issue and

potentially violated.

72

Defendant Little League failed

to

perform an adequate investigation either

, Individually, or

in

compliance with its own rules, policies or procedures.

73. In December o 2014, Steve Keener, ( Keener ) made public statements clearing

JR W

o

any wrongdoing.

74. Even

i

there were boundary issues with JRW, Keener himself either determined

: that the JRW Tournament Team's eligibility was not violating

o

Little League Rules or

: deliberately canceled the boundary issues

so

that could profit through the unique appeal o the

JRW Tourmament Team

in

its contract with Little League and ESPN.

75. During this period, Chris Janes, Individually and as agent o Evergreen Park

Athletic Association, had filed a grievance with the Little League about the JRW player

residences.

76 According

to

the Little League Rules o play any Protest regarding Rule

violations and player ineligibility must have been raised before the subject Tournament

is

completed.

12


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77. Keener himself publicly acknowledged that no protests or complaints were raised

in a timely manner and in accordance with Little League rules.

78. On information and belief following the success o the JRW Team Defendant

Little League through its agent and CEO Steve Keener entered into a television rights

agreement with ESPN.

79. On or about December 23 2014 Defendant JRWLL through its agent Bill Haley

had attempted to absorb territories around Chicago-land from other leagues

in

order to

retroactively legitimize the eligibility

o

all the JRW Team members.

80. On or about February 11 2015 Defendant Little League announced that it was

• stripping the title from the JRW Tournament Team without giving the JRW Team or the JRW

Parents advance notice due process or an opportunity to be heard and

in

contravention to the

rules outlined

in

the Little League Handbook.

81

Immediately prior to Defendant Little League announcing that the title had been

I stripped ESPN broke the story before any o the JRW players or their families were informed.

I

I

82.

The press release issued by Little League on February 11 20

15

failed to mention

- -- its Official Regulations and/or procedures for stripping the title from the JRW Team.

83. The memorandum sent by Little League to JRW on February 12 2015 also failed

to mention the Official Regulations.

84.

The Official Regulations contain the rules that govern all teams that play Little

League baseball.

85. ESPN continually aired the Jackie Robinson West tournaments and reported on

circumstances surrounding the stripping o the World Series Title from the JRW Tournament

Team.

13


14/26

86. At all times relevant, neither the players on the JRW Tournament Team, nor the

JRW Parents submitted any boundary maps

to

JRWLL or Little League.


JRW Parents accepted any boundary maps from JRWLL or Little League.


JRW Parents approved any boundary maps for JRWLL or Little League.

89 Finally, Defendant Little League misrepresented the facts involved by asserting

that an altered boundary map was the boundary map submitted in the tournaments.

90. In reality, the original JRW Map submitted

to

at the tournaments and

to

· Defendant Little League was true and correct, and for that reason Defendant Little League was

· aware of the eligibility issues with the JRW Players as soon as the original JRW Boundary Map

, was submitted in August

of2014.

COUNT ULTRA VIRES

Against Little League)

1.-90. Plaintiffs repeat and reallege Paragraphs 1 through 90 of Common Facts as

· Paragraphs 1 through 90

of

Count I as though set forth fully herein.

91. The stripping of the World Series Title was contrary

to

the rules and procedures

established by Defendant Little League, thereby not affording Plaintiffs JRW Parents and/or the

JRW Team sufficient due process.

92. Pursuant to the Little League 2014 Baseball Official Regulations with Playing and

Tournament Rules if the facts establishing or verifying the ineligibility

of

a player become

known AFTER [sic] a game, and the ineligible player participated in the game, that team shall

forfeit the game in question, subject to the following conditions: a) A protest may be lodged by

the manager or coach with the Tournament Director or District Administrator.

uch protest

14


15/26

must be made before either team affected by the protest begins another game.

(b) The

Tournament Director or District Administrator must contact the Regional Director (or his/her

appointed agent), who shall contact the Tournament Committee for a decision.

The decision

of

the Tournament Committee shall be

fin l nd

binding. Little League 2014 Baseball Official

Regulations with Playing and Tournament Rules at T-11 Conditions ofTournament Play §C(3)

(emphasis added).

93. No protests were made against the JRW Tournament Team until after the

tournament was completely over; including both national and international tournament play.

94. On information and belief, the facts

of

this matter were never submitted to any

Tournament Committee, but instead the decision was made unilaterally by the administration

of

i

Defendant Little League.

95. Defendant Little League was influenced by bias, prejudice, and/or did not act in

: good faith when it stripped Plaintiffs of the World Series title, and it did not follow the

prescribed procedures.

96. Little League s actions are contrary to rudimentary due process and natural

- justice.

97. As a result ofDefendant Little League s disregard for their own procedures,

Plaintiffs were severely damaged both emotionally and economically when the title was stripped.

WHEREFORE, Plaintiffs, DEVONA

D.

BENTON and FRANK JACKSON,

individually, and on behalfof their minor child, J. B.; ROBERTS BUFFORD, JR., Individually,

and on behalf

of

their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,

individually, and on behalf

of

their minor child, D.B.; VENISA BEASLEY -GREEN and

CHRISTOPHER GREEN, individually, and on behalf

of

their minor child, B.G.; CARLTON A.

15


16/26

HONDRAS,

II

and SHEREE HONDRAS, individually, and on behalf o their minor child, C.H.;

JERRY F HOUSTON and MYRTLE HOUSTON, individually, and on behalf

o

their minor

child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and

on

behalf

o their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf o her minor

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf o their minor

child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf o their minor

child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf o their

minor child, P.R.; SANJA E NOBLE, Individually, and on behalf

o

her minor child, L.N.; and

CLAUDIA HARVEY, individually, and on behalf o her minor child, D.R.; respectfully request

that this Honorable Court award Plaintiffs an amount

in

excess o 50,000.00 for pain and

suffering and lost prospective economic benefits, reinstate the World Series Title to JRW, and

for such other and further relief as this Court deems just and proper.

COUNT UNJUST ENRICHMENT

Against JRWLL and Little League)

1.-97. Plaintiffs repeat and reallege Paragraphs 1 through 97 o Count I

as

Paragraphs 1

through 97 o Count

II

as though set forth fully herein.

98. Defendant JRWLL and Defendant Little League orchestrated and/or concealed

the ineligibility o the JRW Team Members

in

order to reap the benefits o the notoriety and

media attention.

99. Defendant JRWLL and Defendant Little League earned hundreds o thousands o

dollars

as

a result o their concealment and deception.

100

Plaintiffs JRW Parents paid league fees and costs

to

Defendant JRWLL and

Defendant Little League.

16


17/26

·o

LI l

I 0 I. This benefit

of

these earned monies and fees were retained to the detriment

of

JRW Parents.

102. Defendant JRWLL's and Defendant Little League's retention of these benefits

violates the fundamental principles of ustice, equity, and good conscience.

WHEREFORE, Plaintiffs, DEVONA D BENTON and FRANK JACKSON,


behalf of

their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,

and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,

individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and

CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A

HONDRAS, II and SHEREE HONDRAS, individually, and on behalf of their minor child,

C

H ;

::

JERRY

F

HOUSTON and MYRTLE HOUSTON, individually, and on behalf

of

their minor

~ < ~ < )

....:IO Oit


18/26

103 Defendant JRWLL through its agents Bill Haley and Annie Haley deliberately

ignored and/or concealed the eligibility problems

o

the JRW Tournament Team in conjunction

with Defendant Little League in order

to reap the rewards o the short-lived fame and media

attention.

104 Defendant Chris Janes individually and as agent, servant, or employee

o

Evergreen Park Athletic Association, and Evergreen Park Athletic Association, individually and

through its agent, servant, or employee Chris Janes, intentionally investigated the JRW

Tournament Team and delayed until after the tournament was over to raise their complaints.

105 Defendant Little League despite reviewing the boundary map and eligibility

documents o the JRW Parents failed to alert any

o

the parents or coaches that the JRW players

1 were ineligible

to

play.

106

Defendant JRWLL and Defendant Little League failed

to

act until after JRW

Tournament Team won the Little League World Series.

107 Furthermore, following the discovery

o

the residency problems, Defendant Little

: League failed to follow appropriate prescribed procedures and stripped Plaintiffs World Series

Title without due process

o

law.

108

Subsequently, JRWLL through its agent Bill Haley perpetuated the distress by

stating that he was organizing a petition to send to Defendant Little League in an attempt to

reinstate the title.

109 Despite the players and family having collected thousands o signatures and

delivering them to Bill Haley, JRWLL failed

to

send those petitions to Defendant Little League.

110 On information and belief, these petitions were nothing more than a fiction

created by Defendant JRWLL to placate the JRW Parents.

18


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0

u l

Il l . ESPN then failed to heed the warning ofDefendant Little League and released the

news that the JRW Team was being stripped

of

its title before the team even knew.

112. The young players first became aware through the news that the title they had

worked

so

hard

to

achieve had been stripped from them over an alleged technicality.

113. In the ensuing media coverage, ESPN and Stephen Smith accused the JRW

Parents

of

falsifying documents and perpetrating a fraud upon the Little League.

114. Those statements were patently false and were baseless and without merit.

115. All of these events were deliberate acts by Defendants, while they ignored the

well being

of

Plaintiff JRW Parents and their participating minor children.

116. The conduct ofDefendants referenced above was extreme and outrageous.

l ::1 117. Defendants knew or had reason to know that there was a high probability that

~ < Q O M

• . . . . l o ~ ;

•

: ; § g .

their conduct would cause the JRW team members severe emotional distress.

U\O_J

ZO ~ lb

~

118. Plaintiff JRW Parents, Individually and on behalf

of

their minor children, have

: : : ; ; ~

1- -NQ. . ;

~

•

:

been severely emotionally damaged as a result ofDefendants conduct. .

u . l

WHEREFORE, Plaintiffs, DEVONA D BENTON and FRANK JACKSON,


behalf

of their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,

and on behalf

of

their minor child, C.B.; DAR OLD BUTLER, SR. and DO NIT A BRUCE,


of

their minor child, D.B.; VENISA BEASLEY-GREEN and

CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON A

HONDRAS, II and SHEREE HONDRAS, individually, and on behalf

of

their minor child, C.H.;

JERRY

F

HOUSTON and MYRTLE HOUSTON, individually, and on behalf

of

their minor

child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and on behalf

of

their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf

of

her minor

19


20/26

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor

child, P.J.; TAMMY KING and EDDIE KING, SR., Individually, and on behalf of their minor

child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their

minor child, P.R.; SANJA

E

NOBLE, Individually, and on behalf of her minor child, L.N.; and

CLAUDIA HARVEY, individually, and on behalfofher minor child, D.R.; respectfully request

that this Honorable Court award Plaintiffs an amount in excess

of

$50,000.00 for pain and

suffering, award amounts due for lost prospective economic benefits, reinstate the World Series

Title upon the JRW, and for such other and further relief as this Court deems just and proper.

COUNT

IV-DEFAMATION

P R S

(Against Defendants ESPN, Inc.

and

STEPHEN

A

SMITH)

1.-118. Plaintiffs repeat and reallege Paragraphs 1 through

118

of Count III as Paragraphs

1 through

118

of Count IV as though set forth fully herein.

119 On or about February

11,2014,

ESPN2 aired an episode

of First

Take with

Stephen A Smith.

120 During that episode, Stephen

A

Smith directly accused the JRW Parents

of

perpetrating a fraud against the Little League.

121 Specifically, Stephen A Smith stated that the JRW Parents falsified documents

and engaged in deceit when referencing the ineligible residences of the players.

122. Stephen

A

Smith stated that the picture ofDarold Butler was throw kids into the

wind like this and that his face should be put on the screen and treat[ed] it like the mug shot it

deserves to be treated like.

123

Stephen

A

Smith, Individually and as agent, servant, or employee of ESPN,

defamed and slandered Darold Butler by indirectly and directly stating that he had engaged in

criminal, fraudulent acts.

20


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0

U l

124 Stephen A. Smith Individually and as agent servant or employee of ESPN

accused the JRW Parents of falsifying documents and perpetrating a fraud upon the Little

League.

125 Stephen A. Smith Individually and as agent servant or employee of ESPN

defamed the JRW Parents by indirectly and directly stating that they had engaged in criminal

fraudulent acts.

126 These statements and inferences by Stephen A Smith and ESPN were false when

made and Defendants Smith and ESPN knew or had reason

to know that they were false when

made.

127

The statements of Stephen

A

Smith showed a reckless disregard for the

d

individuals involved and the facts

of

the case

.

: - l ~ ~

....

l


22/26

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf

of

their minor


child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf

of

their

minor child, P.R.; SANJA E. NOBLE, Individually, and on behalf

of


CLAUDIA HARVEY, individually, and on behalf

of

her minor child, D.R.; respectfully request

that this Honorable Court award Plaintiffs an amount in excess

of

$50,000.00 for pain and

suffering, award amounts due for lost prospective economic benefits and loss

of

reputation, and

for such other and further relief as this Court deems just and proper.

COUNT FALSE LIGHT

(Against Defendants Little League, ESPN,

and

Stephen A. Smith)

G

l.-128. Plaintiffs repeat and reallege Paragraphs 1 through

128

ofCount IV as Paragraphs

d

~ ~

~

~

1

1 through

128 of

Count V

as

though set forth fully herein .

....lOoo:t.._.

....l

t ; l ~

0

•

:t:oo N

· U1 N 129. On or about February 11 2014, Defendant Little League stripped

the

mmor

z 8 ~ ' - l ,

. ~ S ; ~

• E < - N

Q.4

Plaintiffs

of

their Championship title.

· ~

'- 1

....l

'- 1

130.

Defendant Little League publically announced that the title had been stripped

because some

of

the team members did not qualify under the residency requirements

of

Little

League.

131. Defendant Little League would go on to discuss that the JRW boundary map had

been altered, and publically questioned the residences

of

the JRW Parents.

132. These acts portrayed the JRW Parents and the minor Plaintiffs in a false light and

damaged their reputation.

133.

On or about February 11, 2014, ESPN2 aired an episode

of

First Take with

Stephen A. Smith.

22


23/26

U l

134 During that episode, Stephen

A

Smith directly accused the JRW Parents of

perpetrating a fraud against the Little League.

135 Specifically, Stephen A Smith stated that the JRW Parents falsified documents

and engaged in deceit when referencing the ineligible residences of the players.

136 Stephen A Smith stated that the picture

of

Darold Butler was throw kids into the

wind like this and that his face should be put on the screen and treat[ ed] it like the mug shot it

deserves

to

be treated like.

137 Stephen A Smith, Individually and as agent, servant, or employee of ESPN,

defamed and slandered Darold Butler by indirectly and directly stating that he had engaged

in

criminal, fraudulent acts.

1 I 138 Stephen

A

Smith, Individually and as agent, servant, or employee

of

ESPN,

~ ~ M

....lC>oo:t


24/26

Darold Butler and the other JRW Parents were tarnished irreparably, and all have been damaged

emotionally and economically as a result.


D



of

their minor child,

J

B.; ROBERTS. BUFFORD, JR., Individually,

and on behalf of their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,

individually, and on behalf of their minor child, D.B.; VENISA BEASLEY -GREEN and

CHRISTOPHER GREEN, individually, and on behalf of their minor child, B.G.; CARLTON

A

HONDRAS,

II

and SHEREE HONDRAS, individually, and on behalf of their minor child, C.H.;

JERRY

F

HOUSTON and MYRTLE HOUSTON, individually, and on behalf of their minor

: child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and

on

behalf

of their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf of her minor

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf of their minor


child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on behalf of their

minor child, P.R.; SANJA

E

NOBLE, Individually, and on behalf of her minor child, L.N.; and

CLAUDIA HARVEY, individually, and on behalf of her minor child, D.R.; respectfully request

that this Honorable Court award Plaintiffs an amount in excess of 50,000.00 for pain and

suffering, award amounts due for lost prospective economic benefits, and for such other and

further relief as this Court deems just and proper.

COUNT

VI-INVASION OF PRIVACY

(Against

CHRIS

JANES, individually

and

as agent, servant,

or

employee

of

Evergreen

Park Athletic Association,

and EVERGREEN

PARK ATHLETIC ASSOCIATION,

individually and through its agent, servant, or employee Chris Janes

1-142. Plaintiffs repeat and reallege Paragraphs 1 through

142 of

Count V

as

Paragraphs

1 through 142

of

Count

VI

as though set forth fully herein.

24


25/26

143 The JRW parents home addresses were obtained without lawful authority.

144

Janes committed

an

invasion or privacy against the JRW parents when he used

their license plates to discover their home addresses to report them to Little League.

145 At all relevant times, Chris Janes knew that the addresses were obtained through

questionable and potentially illegal means.

146

Chris Janes publicized Plaintiffs private addresses and information

to

Defendant

Little League.

14

7 As a result o the actions o Chris Janes, Plaintiffs were publicized

in

a false light

and painted as criminals.

148 As

a direct and proximate result o the actions o Chris Janes, individually and as

agent, servant, or employee

o

Evergreen Park Athletic Association, and Evergreen Park Athletic

: Association, individually and through its agent, servant, or employee Chris Janes, Plaintiffs were

severely damaged.


D


individually, and on behalfo their minor child, J B.; ROBERTS. BUFFORD, JR., Individually,

and on behalf

o their minor child, C.B.; DAROLD BUTLER, SR. and DONITA BRUCE,


o

their minor child, D.B.; VENISA BEASLEY-GREEN and

CHRISTOPHER GREEN, individually, and on behalf

o

their minor child, B.G.; CARLTON

A

HONDRAS,

II

and SHEREE HONDRAS, individually, and on behalf

o

their minor child,

C H ;

JERRY

F

HOUSTON and MYRTLE HOUSTON, individually, and on behalf o their minor

child, J.H.; EDWARD HOWARD III, and CALANDRA HOWARD, individually, and

on

behalf

o their minor child, E.H.; LINDA SNEED HARRIS, individually, and on behalf o her minor

child, M.J.; NEDRA JONES and ALVIN JONES, individually, and on behalf o their minor

25


26/26

child, P.J.;

TAMMY

KING and EDDIE KING, SR., Individually, and on behalf of their minor

child, E.K.; PRENTISS LUSTER and DARLENE LUSTER individually, and on

behalf of

their

minor child, P.R.; SANJA E NOBLE, Individually, and on

behalf of


CLAUDIA HARVEY, individually, and on

behalf

of her minor child, D.R.; respectfully request

that this Honorable Court award Plaintiffs an amount in excess of 50,000.00 for pain and

suffering, award amounts due for lost prospective economic benefits, and for such other and

further relief as this Court deems just and proper.

i James A Karamanis

I

Shane M. Bradwell

: Kenneth A. Nazarian

I •

1 Barney Karamams, LLP

• Two Prudential Plaza

: 180 N. Stetson, Suite

3 5

: Chicago, Illinois 60601

Phone: 312-553-5300

Attorney No.: 48525

26

Respectfully submitted,

By:

Is

James A. Karamanis

One

of

Plaintiffs' Attorneys

Documents

Jackie Robinson West Lawsuit 1/11/16