Overview
In an entertaining opinion Friday, Judge Abrams granted heavyweight boxer Fres Oquendo $775,000 and injunctive relief against a German promotional firm referred to as Terek, which failed to pay Oquendo his fill purse after a WBA world heavyweight tile match in Chechnya against Ruslan Chagaev. Oquendo lost the fight and, under the parties’ contract, was entitled to a rematch. Judge Abrams rejected Terek's primary defense -- that the contract was unenforceable -- and, in addition to awarding Oquendo his payment shortfall, enjoined Terek from promoting any bout for Chagaev within the next 18 months unless it first scheduled the promised rematch. She explained that an injunction was appropriate in these circumstances because of the unique nature of a title fight:
[T]he record is clear that Oquendo would suffer irreparable harm that cannot be remedied by money damages if he is denied a rematch. No one disputes that, for a professional boxer, “[i]t is almost impossible to overstate the importance of the Heavyweight Championship from a major organization such as the WBA.” There is, most notably, the chance of the intangible reward of a place in boxing history. With its boxers of immense size and power, the heavyweight championship is unique among all weight classes in producing fighters that are the stuff of boxing legend. But there are also the incalculable financial rewards that will flow to Oquendo should he become the champion. These rewards would be especially lucrative for Oquendo, because Americans have not fared well in heavyweight boxing over the last decade. Then there is also the issue of Oquendo’s age. A professional fighter has a “short economic life expectancy,”and at 42, the window for Oquendo to compete professionally may soon close. Indeed, in Lewis, Judge Cedarbaum of this Court noted that Lennox Lewis’ age of 35 was highly significant because “his boxing abilities may diminish” within the next two years. 147 F. Supp. 2d at 237. Having only just been narrowly defeated by the reigning world heavyweight champion, Oquendo is obviously still able to compete at the highest levels—but that skill will not last forever. His age thus militates in favor of injunctive relief. The balance of hardships also tips decidedly in Oquendo’s favor. Unlike Lewis, where the court was confronted with the balance of hardships between two boxers—each of whom had their careers on the line—this case asks the Court to weigh the interests of a boxer against a commercial entity. As Judge Lynch recognized when he was a member of this Court, while it is the boxer who walks into the ring to engage in physical combat, “[f]or everyone else, all that is at stake is money.”
