Benton v. Little League Baseball, Inc.

An all African-American baseball team from Chicago's South Side won the U.S. Little League World Series title in 2014, but 6 months later was stripped of the title amid allegations of residency rule violations. Parents/guardians filed suit, and team manger and head coach (also a parent) filed several counts individually. Because Plaintiffs have not alleged that Defendants' conduct caused any physical injury or impact to parents, they have not stated a cause of action for direct victim negligent infliction of emotional distress. Allegations of intentional infliction of emotional distress as to the parents are insufficient, as allegations to not show that Defendants' actions were extreme and outrageous. Statements in Little League's press release are not defamatory per se, but are subject to the innocent construction rule.Court properly dismissed Plaintiffs' false light claims.Court properly dismissed civil conspiracy count, given absence of facts showing that there was an actual agreement among Defendants to conceal the claimed eligibility problems. Court erred in dismissing counts for breach of implied contract and promissory estoppel, as reinstatement of the championship title is a possible remedy.(PUCINSKI and COGHLAN, concurring.)