Hicks v. PGA Tour, Inc., 897 F.3d 1109 (9th Cir. 2018)
Professional golf caddies sued the PGA Tour, contending they should not be compelled to wear bibs featuring advertising sold by the Tour and local hosts of the PGA tournaments. The caddies allege contract, quasi-contract, publicity and unfair competition claims under California law, a false endorsement claim under the Lanham Act and antitrust claims under the Sherman Act. The district court dismissed all of the caddies’ claims with prejudice, which the Ninth Circuit affirmed along with issuing an order remanding the case to allow the district court to reconsider whether to grant the caddies leave to amend their federal antitrust and California unfair competition claims. The Ninth Circuit further held that the district court properly concluded that the caddies had consented to wearing the bibs and that they did not do so under economic duress.