NFL Arbitrator Rules No Collusion On Guaranteed Contracts, But League’s Influence Was Clear

In a behind-the-scenes battle that could reshape how future NFL player contracts are negotiated, a key arbitration ruling from earlier this year has come to light, revealing that while NFL owners may not have formally colluded, they were certainly nudged in one direction by league officials.

The decision, made on January 14, 2025, by arbitrator Christopher Droney and recently published on the “Pablo Torre Finds Out” podcast, addressed a grievance filed by the NFL Players Association (NFLPA) in 2022. The union alleged that NFL teams, with backing from the league office, had worked together to suppress fully guaranteed contracts following the groundbreaking deal awarded to quarterback Deshaun Watson in March of that year.

Although Droney ultimately dismissed the grievance and found that the evidence did not meet the legal threshold for collusion under the collective bargaining agreement (CBA), his ruling did not come without strong words for the league. According to Droney, the NFL “contemplated and invited” collective action to limit the spread of guaranteed money in player deals — a clear warning signal, if not a red flag.

The Spark: Deshaun Watson’s Massive Deal

The story begins with Deshaun Watson’s fully guaranteed $230 million deal signed with the Cleveland Browns in March 2022. That contract — unprecedented in NFL history — sent shockwaves through front offices across the league.

It also set the stage for turmoil.

Shortly after Watson’s deal was announced, several high-profile quarterbacks — Lamar Jackson, Russell Wilson, and Kyler Murray — were either up for extensions or in the middle of contract negotiations. Not one of them would ultimately secure a fully guaranteed contract like Watson’s.

This led the NFLPA to suspect that something bigger was at play — an orchestrated league-wide effort to stifle guaranteed money from becoming a new norm.

What the Arbitrator Found

Droney’s ruling, while not in favor of the union, uncovered some notable behind-the-scenes interactions. He cited evidence that, during the NFL’s annual owners meeting in March 2022 — just one week after Watson’s deal became public — league executives prepared a formal presentation to team owners, warning them of the risks of fully guaranteed contracts.

Emails between league general counsel Jeff Pash and Commissioner Roger Goodell painted a picture of concern. Pash suggested that the top-tier guaranteed contracts were a growing trend, and Goodell agreed, warning that the issue needed to be addressed quickly before it “eroded” important aspects of the CBA.

“The NFL Management Council, with the blessing of the commissioner, encouraged the 32 NFL clubs to reduce guarantees in veterans’ contracts,” Droney wrote.

The presentation included detailed slides showing sharp increases in signing bonuses and salary guarantees since the 2020 season. The message to owners was that rising guarantees could hurt their flexibility under the salary cap and limit future roster management options.

But here’s where the league was careful: Despite the pointed tone of the presentation, league officials repeatedly told teams that any decisions about contracts were theirs to make individually.

That distinction is important. Under Article 17 of the CBA, any agreement — even an implied one — between the league or its clubs to collectively alter contract terms can be considered collusion. But warning owners of future consequences is not the same as instructing them to act in lockstep.

Why the NFLPA Filed Its Grievance

In October 2022, the NFLPA launched the arbitration case, arguing that the league had clearly crossed the line. The union was especially troubled by the timing of the March 2022 owners meeting and a series of contract negotiations that followed.

After Watson’s deal, Jackson, Wilson, and Murray all sought fully guaranteed contracts — and all three were denied.

The union believed that the presentation at the owners meeting had successfully influenced the negotiating posture of multiple clubs, resulting in a league-wide resistance to fully guaranteed deals. This, they claimed, was a violation of the anti-collusion provisions in the CBA.

The NFLPA also pointed to a July 2022 text message from Chargers owner Dean Spanos to Cardinals owner Michael Bidwill, congratulating him on signing Murray to a deal that wasn’t fully guaranteed. Spanos noted that it would make his own upcoming talks with quarterback Justin Herbert easier.

“Cleveland really screwed things up, but I was resolved to keep the guaranteed relatively low,” Bidwill replied.

Owners’ Testimonies Paint a Mixed Picture

During the arbitration hearings, several owners and players testified. Their statements were mixed.

Cardinals owner Michael Bidwill, for instance, said he didn’t recall specific language from the league’s presentation but acknowledged the general message about financial caution. He admitted that he and then-general manager Steve Keim were actively negotiating with Murray’s agent at the time and that the league’s presentation influenced their thinking.

Agent Erik Burkhardt, who represents Murray, testified that after Watson’s deal, a fully guaranteed contract was “very important” to his client. However, the Cardinals were not willing to entertain that possibility.

New York Giants owner John Mara dismissed the idea of collusion, saying the notion that he’d call up another owner to coordinate contract terms was “ridiculous.”

Meanwhile, in his testimony, Roger Goodell denied ever asking any owner to steer away from guaranteed contracts. Patriots owner Robert Kraft — who allegedly had a call with former NFLPA executive DeMaurice Smith about being asked by Goodell to raise concerns at a meeting — also denied being instructed to do so.

Arbitration Ruling: A Gray Area

Ultimately, Arbitrator Droney found that the NFLPA was able to prove one of three legal elements necessary to establish collusion: that the league “invited” coordinated action. But without proof that the clubs acted in concert or reached any formal or informal agreement, the grievance was dismissed in full.

“No damages were awarded,” the ruling stated.

That said, the ruling still shines a bright light on how influence — even without collusion — can alter the marketplace for NFL contracts. The league may not have explicitly told teams what to do, but by planting the seeds of concern in a room full of decision-makers, it arguably steered the conversation in a particular direction.

Source: Arbiter: NFL urged clubs to limit guaranteed deals, didn’t collude

Bigger Than One Case: The Future of NFL Contracts

The implications of the ruling go far beyond Watson, Jackson, Wilson, or Murray. The NFL, like many professional leagues, has long resisted the widespread use of fully guaranteed contracts, preferring more flexible structures with bonuses, performance incentives, and injury clauses.

Watson’s deal briefly threatened to upend that status quo — and the NFL’s swift internal reaction shows how seriously the league took that threat.

Although the union lost this round, the evidence presented may still resonate. The detailed slides, internal communications, and owner testimonies reveal a coordinated mindset within the league, even if no legal collusion occurred.

For players and agents, that means a steeper hill to climb when seeking guaranteed money — but also a blueprint for how to challenge league-wide practices moving forward.

And for the NFL, it’s a reminder that while it may legally avoid the label of collusion, its internal efforts to guide contract trends will not go unnoticed or unchallenged.