Zinn v. Parrish

Leo Zinn (plaintiff) was the agent for NFL cornerback Lemar Parrish (defendant) under an annually renewable contract paying Zinn a ten percent commission for using reasonable efforts to negotiate job contracts, advise on investments, secure tax advice, obtain endorsements, and find off-season work. After the 1973 season, the World Football League's Jacksonville Sharks recruited Parrish; Zinn had initial talks with the Sharks but ultimately negotiated a four-year deal worth $250,000 plus a $30,000 bonus with Parrish's team, the Bengals, who knew of the Sharks discussions. After signing, Parrish told Zinn he no longer needed his services and refused to pay any commission. Zinn sued for breach; the district court ruled for Parrish, and Zinn appealed.

Whether a sports agent who uses reasonable efforts to secure employment contracts for a professional athlete fails to perform under an agency contract that requires only reasonable efforts.