Does a sports league have to observe the terms of an expired collective agreement until they have bargained to an impasse?

MultiRegion, United States of America

The following excerpt is from Caldwell v. American Basketball Ass'n, Inc., 66 F.3d 523 (2nd Cir. 1995):

2 However, the parties to a collective agreement are required to observe the terms of an expired collective agreement until they have bargained to an impasse. NLRB v. Katz, 369 U.S. 736, 82 S.Ct. 1107, 8 L.Ed.2d 230 (1962). In a sports league, if a collective agreement that authorized individual bargaining expired but the status quo was being maintained, individual bargains could take place in the absence of a collective agreement. This exception to the general rule stated in the text does not affect the analysis.

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