91 N.Y.2d 685 (1998)

An oral personal services contract between a fight trainer and a boxer to last “for as long as the boxer fights professionally” provides a definite, legally cognizable duration, removing it from the presumption of at-will employment in New York.

Summary

Kevin Rooney, a boxing trainer, sued Michael Tyson for breach of an oral agreement where Rooney was to train Tyson “for as long as [Tyson] fought professionally” in exchange for 10% of Tyson’s earnings. After a jury verdict for Rooney, the trial court granted judgment as a matter of law for Tyson, holding the agreement was for an indefinite duration and thus terminable at will. The Second Circuit certified the question of definiteness to the New York Court of Appeals. The Court of Appeals held that the duration was sufficiently definite because it was tied to an ascertainable event—the end of Tyson’s boxing career—and thus did not fall under the at-will employment doctrine.

Facts

In 1980, Tyson, then 14, began training under Rooney with Cus D’Amato as his manager. D’Amato and Rooney agreed Rooney would train Tyson without pay until he turned professional. Once Tyson turned pro, Rooney would be his trainer “for as long as [Tyson] fought professionally.” Rooney trained Tyson for 28 months without compensation. Tyson turned professional in March 1985. D’Amato died in 1985 and James Jacobs became Tyson’s manager in 1986. Jacobs issued a press release stating, authorized by Tyson, that “Kevin Rooney will be Mike Tyson’s trainer as long as Mike Tyson is a professional fighter.” In 1988, Tyson terminated Rooney. Rooney sued in 1989, claiming breach of the 1982 oral agreement.

Procedural History

The U.S. District Court for the Northern District of New York initially denied Tyson’s motion for summary judgment. A jury then found in favor of Rooney. The District Court subsequently granted Tyson judgment as a matter of law, concluding the employment contract did not state a definite term of duration. Rooney appealed to the Second Circuit Court of Appeals, which certified the question of whether the oral contract established a definite duration to the New York Court of Appeals.

Issue(s)

Whether an oral contract between a fight trainer and a professional boxer to train the boxer “for as long as the boxer fights professionally” establishes a definite duration or constitutes employment for an indefinite duration within the scope of the at-will rule.

Holding

Yes, an oral contract between a fight trainer and a professional boxer to train the boxer “for as long as the boxer fights professionally” is a contract for a definite duration because the boundaries of the employment period are ascertainable by the beginning and end of Tyson’s professional boxing career.

Court’s Reasoning

The Court reasoned that, in New York, absent an agreement establishing a fixed duration, an employment relationship is presumed to be at-will. This presumption is triggered when an agreement fails to state a definite period of employment. However, the Court emphasized that a definite employment duration does not implicate the at-will employment presumption. While previous cases found terms like “permanent” or “continue indefinitely” to be indefinite, the term in this case was different. The court found the durational term understandable and reasonably determinable by fact finders, rejecting the necessity of a determinable calendar date. The court stated, “though the times are not precisely predictable and calculable to dates certain, they are legally and experientially limited and ascertainable by objective benchmarks.” The agreement, actualized for years, was established by the definable commencement and conclusion of Tyson’s boxing career. Therefore, the Court answered that the oral contract was for a definite duration.