Star Athlete's Trainer Loses Commission Bid

A lawsuit alleging a former trainer was entitled to a portion of tennis star Naomi Osaka's lifetime earnings is out of play, after a Broward County, FL, Circuit Court judge dismissed the case. Jean v. Francois, 19002954.

Judge David A. Haimes dismissed the three-count complaint by Christophe Jean, a Pompano Beach tennis trainer who sued Osaka, her sister Mari and her father Leonard Francois for breach of contract and unjust enrichment.

Jean's complaint sought quantum meruit earnings, alleging the trainer had a contract in which the family agreed to pay him 20% of the sisters' earnings over their entire careers in exchange for coaching. He claimed the family had struggled to afford the equipment and private lessons before Osaka became a star athlete with championships in women's singles at the U.S. and Australian opens.

But Judge Haimes ruled that if Jean "wanted to validate the contract, [he] was required to submit the contract to a court for approval."

"Because no court ever approved the subject contract, and Naomi Osaka and Mari Osaka, who were minors, disavowed said contract, the court holds that the subject contract is not valid or enforceable," the judge wrote finding Jean's evidence "on its face fails to specify the required elements for a valid contract."

Judge Haimes dismissed Jean's complaint because Florida courts "have routinely held that one cannot bring a claim for unjust enrichment against a minor." The judge also ruled the same claims brought against Francois failed, too, because the father was "solely acting in his capacity as an agent" for his children.

Representing Osaka and her family were Quinn Emanuel Urquhart & Sullivan New York partners Luke Nikas and Alex Spiro, who's also represented New England Patriots owner Robert Kraft. The attorneys filed a motion to dismiss, arguing Florida law allows child athletes, deemed "infants" to later void their contracts.

Jean's legal counsel is Christopher P. Hahn of Fort Lauderdale law firm Maurice Wutscher.

Jean's lawsuit claims the training arrangement began in March 2012 and concluded five years later in April 2017. It alleged Jean had "not received any income derived from defendants' tennis careers, including but not limited to, Women's Tennis Association prize money and endorsement deals," necessitating his legal action.

Jean also claimed his contract with the defendants "provided that the term of the employment shall be indefinite, and the agreement may be terminated by giving three months' written notice to the other party."

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Zach Schlein is the litigation reporter for Daily Business Review, an affiliate publication of Entertainment Law & Finance. He can be reached at [email protected].