Kansas City Chiefs, Consider Yourself Served

United States Supreme Court

ARROWHEAD PRIDE et al

v

KANSAS CITY CHIEFS

This action arises under recent federal law as recently put forth in Restatement (Second) of Torts, Section 46:

#46.  OUTRAGEOUS CONDUCT CAUSING SEVERE EMOTIONAL DISTRESS

"(1)One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress. The actor is also liable to such person's immediate family members who are present at the time of the conduct."

In the following action for specific performance, we shall demonstrate how Todd Haley, Bill Muir, and other members of defendant's organization have performed in such a manner as to cause severe emotional distress to thousands of fans, represented as Arrowhead Pride et. al. in this action.

1.  "Extreme and Outrageous" conduct under this tort is recognized as any intentional action which goes beyond all possible bounds of decency, and is utterly intolerable in a civilized community. A commonly held standard is if such conduct would cause a member of the community to resent the actor and exclaim, "That's outrageous!"

2.  Arrowhead Pride is widely recognized as a community of the fans, representative of the feelings and opinions of Chiefs fans as a whole.

3.  Multiple members of Arrowhead Pride have called the recent actions of certain Kansas City Chiefs players outrageous, and have pointed out that the conduct of said employees is utterly intolerable.  These employees and their actions follow.

4.  Todd Haley, the head coach of the defendant organization, on the dates of September 11, 18, and 25, did start and play Matt Cassel for the entirety of the football games that were scheduled that day. This is despite terrible play on the part of Mr. Cassel and the large deficits that arose in said games.

5.  Bill Muir, another employee of the defendant, on the date of September 11, fell asleep during the game despite his duties as offensive coordinator/Haley’s Puppet.  While this act may have benefited more than hurt the team, the conduct is still outrageous enough to fall under Section 46.

6.  Mr. Haley and Mr. Muir, despite having an elite RB group including Jamaal Charles (up until the unfortunate injury to Mr. Charles), chose to only run the ball 18 times in the September 11 game against the Buffalo Bills.  They chose rather to allow Mr. Cassel to throw the ball 36 times despite his horrible 3.3 YPA average. 

7.  Romeo Crennel, defensive coordinator for defendant, has in every game mentioned in this complaint chosen to use Cameron Sheffield as a pass rusher in obvious passing downs rather than Justin Houston.  This decision has been made despite Mr. Houston’s clear superiority in every facet of the game.

8.  Mr. Crennel also, in the first and second games of the year, kept Wallace Gilberry in the game in situations where the other team could run the ball.  This was in place of Tyson Jackson, a much more capable run defender.  The results speak for themselves in those two games, as Mr. Gilberry was dominated in those situations.

9.  Mr. Haley, with intent, did give Thomas Jones 14 carries on September 25 while only giving fellow running back (and vastly superior runner) Le’Ron McClain 2 carries.

10.  Mr. Cassel has shown an inability to consistently (or even more than occasionally) make throws beyond 5 yards. 

11.  More crucially, Mr. Cassel has shown repeatedly an inability to look beyond his first wide receiver when trying to find an open man on the field.  This habit has resulted in every receiver the Chiefs place on the field but one being made irrelevant on any given play (for specific evidence, plaintiffs will be bringing forth game film showing Steve Breaston only getting the ball thrown to him once Dwayne Bowe was taken out of the game with an injury). 

12.  Mr. Cassel has also demonstrated the inability to throw to his left.  Given that half the football field is in that direction, this has resulted in a clear detriment to his team.

13.  Mr. Cassel has shown skittishness in the pocket that has directly resulted in bad throws, broken plays, sacks, and overall inefficiency on the part of the offense

14.  Mr. Haley, despite these weaknesses, has refused to even acknowledge a problem with defendant’s quarterback situation, or even give Ricky Stanzi significant practice repetitions to compete with Mr. Cassel.  Keep in mind this in spite of the fact that Mr. Cassel has done nothing Mr. Stanzi could not do, and has shown multiple weaknesses that Mr. Stanzi is not known to possess

15.  The Chiefs’ offense failed to register a first down in the game dating September 25 against the San Diego Chargers. 

16.  Plaintiffs have been subjected to these and more decisions made by employees of the defendant organization.  Given the rabidity of plaintiffs' devotion to the Chiefs, these decisions and others like them have been the source of severe emotional distress and has even been seen to cause mental damage in the condition known as "Luckitis," in which the person becomes incapable of anything but posting pictures of or comments about Andrew Luck, a well-known college quarterback.  Plaintiffs are prepared to call an expert witness (Professor hmills) to confirm the existence and severity of this condition.

17.  Plaintiffs have suffered through years of losing, causing severe damage to their mental and emotional well-being. 

18.  Plaintiffs families have witnessed this suffering every Sunday for as long as most can remember.  The witnessing of such devastating emotional distress has taken a toll on spouses in particular as they are the ones left to care for the at-times catatonic plaintiffs.

19.  For the aforementioned reasons, plaintiffs demand judgment in the form of specific performance.  This performance would be ordered by the court as damages for the emotional distress caused by the defendant’s employees, and would come in several parts.

First, Mr. Haley shall immediately begin giving Mr. Stanzi more significant practice time, and insert him into the game as the Chiefs’ quarterback within several weeks (sooner if possible).  This will serve to relieve the emotional distress for plaintiffs as they could see what they have in Mr. Stanzi and thus determine the best course of action for the team in the 2012 NFL draft.  In addition, this step may enable the Chiefs to truly use more than one wide receiver in a given play, as well as look for players downfield on a consistent basis.

Second, Mr. Haley and Mr. Muir shall immediately give Mr. McClain no less than half of the carries that have been going to Mr. Jones.  Such a commonsense step is no less than the plaintiffs deserve to mitigate their suffering.  Game plans will be based on the ability to run the ball and play good defense, and will center around the talents of Mr. McClain and Dexter McCluster.

Third, Mr. Crennel shall immediately begin keeping Mr. Houston in the game during obvious passing downs, which will allow Mr. Houston and Tamba Hali to wreak havoc during every snap played. 

Fourth, Mr. Crennel shall immediately activate Jerrell Powe and allow him to gain valuable experience on the field.   Mr. Crennel shall also be required to play him next to Kelly Gregg on at least several defensive snaps a game.

Fifth, the defendant’s main employee, Scott Pioli, shall be directed to immediately find a replacement for Sabby Piscitelli and remove him from the team.

Sixth, Mr. Pioli shall be directed to take a franchise quarterback in the 2012 NFL draft should Mr. Stanzi prove unable to shoulder the load of being said quarterback.  In the event that Mr. Stanzi proves himself capable, Mr. Pioli shall be directed to take the best player available at any of the following positions: offensive line, defensive line, or inside linebacker. Who this player is will be determined by a committee featuring 5 members of Arrowhead Pride.

(Yeah, I’m doing the entire end of my post in parentheses.  It’s happening.  Wanna know something crazy? This is an actual, existing, cause of action.  And seriously, the standards for it are the ones I set forth at the beginning of this post!  Am I crazy, or could we actually have a case here?  OK, yes, a judge would throw it out instantly because it’s football.  But let me ask you, if you brought this before a judge who is FROM Kansas City… wouldn’t you at least have a shot?)