In January 2025, an arbiter ruled that NFL teams did not collude to restrict fully guaranteed contracts, dismissing a grievance filed by the NFL Players Association (NFLPA) in 2022. The grievance was rooted in suspicions that clubs acted in unison to resist fully guaranteed contracts after quarterback Deshaun Watson secured a record $230 million fully guaranteed deal with the Cleveland Browns.
Though the decision, revealed by the “Pablo Torre Finds Out” podcast, acknowledged the NFLPA’s concerns, it ultimately concluded no formal collusion occurred under the collective bargaining agreement (CBA).
Arbitrator Christopher Droney did not award any damages or uphold the NFLPA’s claims in full, but he acknowledged that there was “concerted action contemplated and invited” during the March 2022 owners meeting.
Internal emails and presentation materials from the NFL’s management council and Commissioner Roger Goodell indicated the league had actively discussed reducing contract guarantees. However, Droney found insufficient evidence for the two other legal elements required to prove collusion.
NFLPA Cites CBA Violation as Owners Debate Risks of Guaranteed Contracts Trend
The NFLPA initiated the arbitration in October 2022, following the inability of several top quarterbacks — Lamar Jackson, Russell Wilson, and Kyler Murray — to secure fully guaranteed contracts despite Watson’s precedent-setting deal.
The union argued this constituted a violation of Article 17 of the CBA, which prohibits any express or implied agreements between clubs to influence contract terms. They believed the league acted to suppress the emergence of fully guaranteed deals.
NFL Teams Cleared of Collusion in Guaranteed Contracts Case, Arbitrator Dismisses NFLPA GrievanceAccording to the arbitration ruling, NFL executive vice president Jeff Pash informed Goodell via email in March 2022 that contract guarantee trends should be addressed at the owners’ meeting. Goodell agreed, citing concern over the long-term implications for the CBA.
The management council’s presentation to club owners included graphs and slides warning of the salary cap risks posed by rising contract guarantees, suggesting unchecked trends could constrain future roster flexibility.
During the arbitration hearing in mid-2024, some owners, including Michael Bidwill of the Cardinals and John Mara of the Giants, testified regarding the March 2022 meeting.
Bidwill said he didn’t recall the exact details of the presentation but acknowledged it likely influenced discussions with then-general manager Steve Keim about Kyler Murray’s extension. Mara dismissed the idea of collusion among owners as “ridiculous,” emphasizing the independence of club decisions.
Top Quarterbacks Denied Full Guarantees Despite Watson Precedent and NFLPA Allegations
Despite efforts by agents like Erik Burkhardt (representing Murray) to secure fully guaranteed contracts after Watson’s deal, teams resisted. Murray eventually signed a five-year extension that was not fully guaranteed.
A congratulatory text from Chargers owner Dean Spanos to Bidwill later revealed that non-guaranteed contract terms for Murray were viewed as beneficial in setting a league-wide tone, especially ahead of negotiations with other quarterbacks like Justin Herbert.
Lamar Jackson, Russell Wilson, and others testified in arbitration about their efforts to negotiate guaranteed deals. Jackson received shorter-term guaranteed offers from the Ravens but ultimately signed a longer non-fully guaranteed contract. Wilson said he pushed for full guarantees from Denver but was rebuffed.
Arbitrator Droney noted Denver had leverage due to Wilson still being under contract for two more years, making a fully guaranteed deal unlikely from the outset.
The NFLPA also claimed that Goodell, through Patriots owner Robert Kraft, attempted to influence other owners in August 2022 to reject fully guaranteed contracts. DeMaurice Smith testified that Kraft had told him about such a conversation.
However, both Goodell and Kraft denied these claims under oath. Droney ultimately found no credible evidence to support the allegation, further undercutting the NFLPA’s argument that collusion had occurred.
