Paradigm Sports Management wins $5.1M judgment against Manny Pacquiao; appeal expected
An Orange County, California, Superior Court jury awarded Paradigm Sports Management a judgment of $5.1 million against legendary boxer Manny Pacquiao after a lengthy breach of contract trial, though Pacquiao's side said the case is not over and the crux of the matter has yet to be heard.
The judgment was for $3.3 million in actual damages for money paid to Pacquiao by Paradigm, as well as for $1.8 million in punitive damages. Paradigm had signed Pacquiao to a contract and discussed fights with boxer Mikey Garcia and MMA star Conor McGregor with him, but neither materialized.
Garcia testified at trial that Paradigm discussed a Pacquiao fight with him, but a deal was never reached.
Pacquiao's side insisted after the 9-3 jury decision in Paradigm's favor that a key piece of evidence was not heard. On April 20, after Paradigm rested, Pacquiao's attorneys introduced a motion that said the contract between Paradigm and Pacquiao was invalid because it was not filled out on California State Athletic Commission (CSAC) paperwork, as is required, and the sides did not appear in front of the commission's executive officer, Andy Foster, to sign the deal, as is required.
The motion, called a judgment of nonsuit, will be heard in June. Former MMA world champion Ronda Rousey won a case against her manager, Darin Harvey, in 2014 on a similar basis. Rousey alleged in her suit that she and Harvey did not appear in person in front of the commission to validate their contractual agreement and, therefore, the deal was invalid.
One key difference between the Rousey/Harvey case and the Pacquiao/Paradigm case is that Rousey was licensed by CSAC at the time of the dispute with Harvey. Pacquiao was not licensed by California at the time his contract with Paradigm was signed.
Foster, then as now the commission's executive officer, invalidated the managerial contract between Rousey and Harvey. In his finding, Foster relied upon Title 4, Rule 222 of the California Code of Regulations entitled Execution of Contract. It states:
"Unless otherwise directed by the commission, a contract between a boxer and a manager or a boxer and a promoter is not valid unless both parties appear at the same time before the commission or a commission representative and it receives written approval. No contract shall be approved between a manager and a boxer or a promoter and a boxer for a period exceeding five years. No option to extend the initial period shall be permitted."
Foster also alluded to Rule 220, which reads:
"Contracts between boxers and managers and between boxers or managers and licensed clubs shall be executed on printed forms approved by the commission. The commission may recognize or enforce a contract not on its printed form if entered into in another jurisdiction. No other contract or agreement may be recognized or enforced by the commission."
Pacquiao said his contract with Paradigm was not completed on the appropriate California State Athletic Commission forms. Pacquiao's attorneys submitted the request for judgment of nonsuit on April 20. Judge Walter P. Schwarm tabled the request and let the trial complete. After deliberations began Monday, the jury found for Paradigm on Wednesday.
“We are elated to learn of the jury's ruling in Paradigm's favor in our suit against Manny Pacquiao," Attar said in a statement. "The jury plainly found that Pacquiao testified falsely in denying Paradigm’s claims against him, and his excuses for his conduct proves our case that a breach of contract was committed.
"We are appreciative of the court's time and the jury’s careful attention to the facts of this case. Hopefully, Manny will have learned a lesson from the verdict and will henceforth act with the honesty and integrity that was so lacking in his treatment of Paradigm.”
Pacquiao won championships in eight weight classes and is one of the highest-earning boxers of all time. In 2006, he signed with both Top Rank and Golden Boy Promotions, accepting a briefcase with $250,000 from Golden Boy's Oscar De La Hoya as an inducement to sign when it turned out he already had a promotional agreement with Top Rank. That went to an arbitration, and a former judge gave both parties rights. Top Rank promoted Pacquiao's fights until the end of the contract, but Golden Boy earned money off the matches.
Pacquiao attorney Jason Aniel said in a statement that the jury's decision Wednesday is far from the final word in the case.
"A judgement has not yet been entered," Aniel said in his statement. "The court has scheduled a hearing in June and there are still legal issues that need to be addressed by the court before the case is fully resolved. We look forward to the final decision by the court."
Pacquiao declined comment until the case is complete.