Breaking Down the Red Sox Boycott; Youkilis on the Parol Evidence Rule

The Boston Red Sox closed their spring training with an off-field drama demonstrating that professional sports and business go hand-in-hand.  The Sox players, apparently miffed that coaches and team staff members would not receive a stipend to travel to Japan for the opening day, staged a boycott of the team’s last spring training game.  The boycott lasted over an hour before it was resolved and the Sox took the field.  The situation raised many questions and prompted many confusing reports.  The following attempt to break down the issues:

  1. What was the dispute about?  When the Red Sox players agreed to play their opening series in Japan, the Major League Baseball Players’ Association (the “Players’ Association) negotiated a payment of $40,000 to each player.   The players, based on a conference call with the Players’ Association last October, believed that coaches and team staff would also receive the payment.  However, such a provision was missing from the written agreement.
  2. How were Coaches and Staff Left Out?  The Players’ Association, as its name suggests, represents players, not coaches and staff members.   However, the players believed that the provision to pay the coaches and staff was negotiated and included in their agreement with Major League Baseball.  Red Sox manager Terry Francona apparently told his coaches and staff that they were in line to receive the stipend.  The Players’ Association, however, left the provision out of the written agreement.
  3. How was the dispute resolved?  The players formed a unified front and negotiated directly with Sox management, which agreed to fund the payments, which amount to nearly $600,000.  Ultimately the Red Sox expect to be reimbursed at least in part by Major League Baseball and/or the Players’ Association.

Beyond the pure intrigue, his dispute invoked a basic common law rule of contracts.  A written contract embodies the complete agreement between the parties and cannot be modified or challenged by additional, oral terms.  This concept, referred to as the parol evidence rule, is perhaps best described by Sox first baseman Kevin Youkilis:

“I think the next time we know going forward that when you have these conference calls, you have to get it in writing.  It’s the easiest way to do stuff.” (emphasis added)

 With the resolution of the dispute, word is that Commissioner Bud Selig will not discipline the Sox players for boycotting their last spring training game for over an hour.  I assume that the Commissioner has more pressing matters to handle.


  1. Great post! Thanks…

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