The following excerpt is from Caldwell v. American Basketball Ass'n, Inc., 66 F.3d 523 (2nd Cir. 1995):
2 However, the parties to a collective agreement are required to observe the terms of an expired collective agreement until they have bargained to an impasse. NLRB v. Katz, 369 U.S. 736, 82 S.Ct. 1107, 8 L.Ed.2d 230 (1962). In a sports league, if a collective agreement that authorized individual bargaining expired but the status quo was being maintained, individual bargains could take place in the absence of a collective agreement. This exception to the general rule stated in the text does not affect the analysis.
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