USA Rugby Lawsuit Dismissed Without Prejudice Due to Lack of Subject-Matter Jurisdiction

Strategic Insights -

The United States District Court for the Western District of Texas has issued an opinion dismissing the lawsuit brought by National Collegiate Rugby (NCR) against USA Rugby and Jamie McGregor. The complaint alleged violations of the Ted Stevens Act, as well as tortious interference, defamation, and fraud by omission. However, the court found that NCR lacks a federal private cause of action, and its state-law claims are preempted by the Ted Stevens Act.

Key Takeaways:

  • The court dismissed NCR's Ted Stevens Act claims due to the lack of a private right of action under the Act.
  • The Ted Stevens Act preempts NCR's state-law claims for tortious interference, defamation, and fraud by omission, as well as the Texas Deceptive Trade Practices Act.
  • The court declined to reach NCR's Motion for Partial Summary Judgment.
  • NCR's claims were dismissed without prejudice due to the lack of subject-matter jurisdiction.
  • The court is obligated to dismiss claims for lack of subject-matter jurisdiction, and dismissals should be without prejudice to refiling in a forum of competent jurisdiction.

Statistics:

  • Over 600 college teams and thousands of players were affected by USA Rugby's alleged attempts to collect dues from NCR's member teams.
  • NCR brought claims for violations of the Ted Stevens Act, as well as tortious interference, defamation, and fraud by omission.
  • The court referred the motions to United States Magistrate Judge Mark Lane.
  • Plaintiff timely objected to the report and recommendation, securing de novo review by the district court.

Sources:

  • National Collegiate Rugby v. USA Rugby and Jamie McGregor, Case No. 1:25-cv-00269-RP (Western District of Texas, Austin Division)
  • Report and Recommendation of United States Magistrate Judge Mark Lane, (Dkt. 27)
  • Text Order, (Undated)
  • Objections to Report and Recommendation, (Dkt. 28)
  • Response to Report and Recommendation, (Dkt. 29)
  • Reply to Objections, (Dkt. 32)
  • Carver v. Atwood, 18 F.4th 494 (5th Cir. 2021)
  • Federal Rule of Civil Procedure 12(h)(3)