Jimmy Williams (“Williams”), a former University of Minnesota (“UM”) basketball coach from 1971 to 1986, was approached by Tubby Smith (“Smith”) about returning to UM as an assistant basketball coach. At the time, Smith was still employed as the head basketball coach by the University of Kentucky, but was considering moving to UM. Shortly thereafter, Smith accepted the heading coaching job at UM and again contacted Williams to join his staff. The two talked over the course of the following weeks about the position and Smith ultimately offered Williams an opportunity to join his staff. After offering Williams the position, Smith informed Williams that UM’s athletic director had to “sign off” on his hiring, but Smith conveyed that he did not believe that would be a problem. Subsequently, Smith informed Williams that UM’s athletic director had reservations about hiring Williams, yet Smith and Williams continued to discuss recruiting assignments. Therefore, Williams believed the position was solidified and he voluntarily terminated his employment with Oklahoma State University to join Smith’s staff at UM.
UM’s athletic director was informed by an administrator that Williams committed several major violations of NCAA bylaws governing student-athlete amateurism during his previous tenure at UM and was twice cited by the NCAA for such improprieties. After learning that Williams’ conduct twice placed UM on probationary status with the NCAA, UM’s athletic director deemed Williams disqualified to serve as an assistant basketball coach at UM. Williams was then informed that he was not going to be hired by UM. Since this matter, Williams has not been hired by another institution.
As a result, Williams filed suit against UM, Smith, and UM athletic director Joel Maturi (“Maturi”) asserting claims for breach of contract, promissory estoppel, equitable estoppel, intentional interference with contract, negligent misrepresentation, negligence, defamation, vicarious liability, and due process violations of his property and liberty interests. Prior to trial, all claims against Maturi were dismissed on the grounds of qualified immunity. Initially, all claims were also dismissed against UM and Smith based on the doctrine of separation of power, because Williams was challenging the decision-making process of the executive branch of the government. Williams appealed and the Minnesota Court of Appeal reinstated Williams’ single claim for negligent misrepresentation against UM and Smith.
Williams’ claim for negligent misrepresentation was tried to a Minnesota jury. The jury returned a verdict in favor of Williams and found that 1) Smith falsely represented to Williams that he had final authority to hire assistant basketball coaches at UM; 2) Smith failed to use reasonable care, either in obtaining information pertaining to his hiring authority or in communicating information about his hiring authority to Williams; 3) Williams relied on Smith’s misrepresentations; 4) Williams’ reliance was reasonable; and 5) Williams was harmed by the reliance. Ultimately, the jury awarded Williams $1,237,293.00 in damages. However, the district court modified the damages awarded by the jury in accordance with the Minnesota Tort Claims Act and entered a judgment in favor of Williams in the amount of $1,000,000.00.
On appeal, the Minnesota Court of Appeal issued an unpublished opinion and affirmed the trial court’s ruling. UM and Smith challenged several aspects of the trial court’s decision including that Williams failed to meet necessary elements of his claim for negligent misrepresentation (i.e., duty of care and reliance). Williams also filed a cross-appeal seeking the Minnesota Court of Appeals to reinstate the jury’s award. Ultimately, the Minnesota Court of Appeals did not find either parties’ argument persuasive and affirmed the verdict of the lower court.