Entitled to a Second Opinion, Deprived of a Second Chance: Christian Wilkins’s Legal Battle with the Las Vegas Raiders

By: Halle DeNardo*                                                                          Posted: 10/03/2025

In July 2025, the Las Vegas Raiders unexpectedly released six-year veteran defensive lineman Christian Wilkins, sparking a legal showdown between the NFL Players’ Association (“NFLPA”) and the Raiders organization.[1]  This costly decision occurred after just one season of Wilkins’ four-year, $110 million contract with $82.75 million guaranteed. [2]  Wilkins suffered a foot injury that required rehabilitation, but his refusal to undergo surgery recommended by the team’s medical staff left the Raiders dissatisfied.[3]  This disagreement led to Wilkins’ release, the Raiders voiding the guaranteed money in his contract, and the NFLPA filing a grievance on Wilkins’ behalf.[4]  This legal dispute also introduces ethical concerns regarding a player’s medical autonomy within the NFL, as all NFL players are protected by a Collective Bargaining Agreement (“CBA”) that permits players to seek additional medical opinions outside of the league.[5]  Ultimately, this conflict underscores concerns regarding the enforcement of guaranteed money in contracts when teams release players, as well as the protection of players’ medical autonomy under the CBA, particularly in situations where team doctors’ recommendations conflict with independent medical opinions.[6]

Grievances & Guaranteed Money Contracts

The NFLPA filed its grievance on behalf of Christian Wilkins when the Raiders terminated his contract and voided the remainder of his $35.2 million guaranteed money.[7]  Christian Wilkins had already played in five games in the 2024 NFL season, which earned him almost $50 million of his $82.75 million guaranteed from the Raiders.[8]  This amount includes his original $24 million signing bonus, his first-year base salary of $5 million, plus his $20.5 million roster bonus.[9]  The $32.5 million in dispute comes from the $8 million he was guaranteed as a base salary at the start of this season, as well as the $27.25 million that was guaranteed for the 2026 season to help the Raiders for salary-cap purposes.[10]  There are two types of grievances a player can file: an injury grievance and a noninjury grievance.[11]  While this matter concerned Wilkins’ Jones fracture suffered during his first season with the Raiders, the grievance actually concerns the disagreement between Wilkins and the Raiders regarding his rehabilitation that ultimately led to his release.[12] Therefore, since this grievance addresses the Raiders’ decision to void the guaranteed money in Wilkins’ contract because of the medical disagreement, this matter is actually a non-injury grievance.[13]  When a player seeks to file a grievance for a noninjury issue, he has fifty days from the date of the event that prompted the grievance, which Wilkins and the NFLPA have timely filed.[14]

Moreover, guaranteed money in NFL contracts has certain provisions that protect a player’s compensation in the event of termination.[15]  There are three well-known guarantees in NFL contracts: skill, cap, and injury guarantees.[16]  Relevant to Wilkins’s contract, under an injury guarantee, if a player is unable to perform football duties as a result of team activities, he is still entitled to the money guaranteed in his contract.[17]  Wilkins suffered a Jones fracture during the 2024 season and started the 2025 season on the Physically Unable to Perform list (“PUP”).[18]  The team released Wilkins, citing “no clear path or plan for future return,” and argued that Wilkins failed to maintain his physical condition to play after declining a second foot surgery they recommended.[19]  Because he did not follow his prescribed rehabilitation plan, the Raiders argue that his injury does not fall under “injuries from team activities,” thus allowing the team to void the $35.2 million guaranteed money remaining in Wilkins’ contract.[20]  This raises concerns about the enforcement of guaranteed money in contracts, as the NFL and other leagues may attempt to exploit loopholes in contract language to avoid their obligation to pay out guaranteed compensation.[21]  Wilkins maintains that he is entitled to the guaranteed money, hence filing the grievance to challenge the team’s decision.[22]  Up next is an arbitration hearing, which has yet to be scheduled.[23]  With the injury guarantee provision in his contract, it seems as though the Raiders will have an uphill battle to fight.[24]

Collective Bargaining Agreement

One of the major questions stemming from this dispute is whether Wilkins truly needed a second foot surgery.[25]  Article 39, Section 6 of the NFL’s CBA states that “a player will have the opportunity to obtain a second medical opinion” and has the right to follow that medical advice with respect to his diagnosis, injury, or rehabilitation.[26]  However, this can only occur after consulting with the Club’s physician and giving proper consideration to their original recommendation.[27] Here, if Wilkins obtained a second opinion contradicting the recommendation for a second foot surgery, he has the right to follow that advice.[28]  It remains unclear whether Wilkins sought medical opinions outside the league, as some sources reference only the broader dispute between Wilkins and the Raiders, while others specifically assert that he declined multiple medical examinations and opinions.[29]  Seemingly, if Wilkins went against all informed medical recommendations for additional surgery, the Raiders could invoke paragraph 8 of the NFL Player Contract to claim he failed to maintain satisfactory physical condition, effectively using this as a loophole to avoid paying his injury guarantees.[30]  However, Raiders Coach Pete Carroll’s statements may aid Wilkins in the grievance, noting Wilkins has done “everything he needs to do,” worked hard, complied with monitoring, and has “been on board the whole time.”[31]  Again, the dispute underscores how teams can exploit vague contract language to escape guarantees that appear secure.[32]  Yet, with uncertainty over whether Wilkins obtained a second opinion, not that it is necessary to do so, the Raiders’ decision to void his guarantees risks not only appearing as a contractual loophole but also exposing the team to potential breach if Wilkins satisfied his obligations under the CBA.[33]

Ethical Concerns: Medical Autonomy

The release of Christian Wilkins due to a disagreement in his path of recovery sparks ethical concerns over the medical autonomy of NFL players.[34]  Specifically, the principle of bioethics—applying ethics to medicine and healthcare—is most often recognized through the concept of autonomy, which can be examined in the context of Wilkins’ situation.[35]  Ethicists have defined autonomy as “self-rule free from controlling interference by others.”[36] Like previously discussed, NFL players are protected under Article 39, Section 6 of the CBA, which allows players to seek alternative medical opinions outside the Club’s medical staff.[37] It is generally understood that this provision entitles players to the right to choose their own course of treatment, consistent with the principle of autonomy.[38]   If Wilkins’ decision to forego the second surgery was medically reasonable, he was well within his rights to decline it.[39]  Therefore, the Raiders’ decision to void $32.5 million in guarantees based on his recovery path raises significant bioethical and legal concerns, as it may represent an infringement on the medical autonomy afforded to players under the CBA.[40]  This could potentially set a bad precedent in the NFL, showing that business and ethics often clash within the league.[41]

*Staff Writer, Jeffrey S. Moorad Sports Law Journal, J.D. Candidate, May 2027, Villanova University Charles Widger School of Law

[1] See Saad Yosef, Explaining Christian Wilkins’ Grievance Against Raiders After His Abrupt Release, Athletic (Jul. 26, 2025), https://www.nytimes.com/athletic/6515836/2025/07/26/christian-wilkins-grievance-raiders-nflpa/ (introducing legal dispute between Christian Wilkins and Raiders after his unexpected release).

[2] See id. (detailing terms of Wilkins’s contract with Raiders and how much guaranteed money his contract had).

[3] See Christopher R. Deubert, Raiders’ Release of Christian Wilkins May Conflict with Medical Autonomy Provided for in CBA, Sports Litig. Alert (Aug. 22, 2025) https://sportslitigationalert.com/raiders-release-of-christian-wilkins-may-conflict-with-medical-autonomy-provided-for-in-cba/ (explaining Raiders’ decision to void Wilkins’ remaining guaranteed money).

[4] See id. (highlighting details in NFLPA’s grievance filed on Wilkins’ behalf).

[5] See Sonny Guzik, Autonomy vs Authority: Christian Wilkins’ Release Sparks NFLPA Grievance Showdown, Raider Ramble (last visited Sept. 27, 2025) https://raiderramble.com/2025/07/26/autonomy-vs-authority-christian-wilkins-release-sparks-nflpa-grievance-showdown/ (presenting legal issues that NFLPA’s grievance raises, as well as other concerns such as ethical concerns and reasons behind Wilkins’ release).

[6] See Cameron Baker & Samuel Finkel, Gambling on Guarantees, JD Supra (Jul. 30, 2025) https://www.jdsupra.com/legalnews/gambling-on-guarantees-1197994/#:~:text=%E2%80%9CWe%20have%20decided%20that%20it,both%20sides%20uphold%20their%20obligations (noting qualities of guarantee money in NFL contracts and how teams use loopholes to get out of their guarantees); see Mike Florio, Right to Second Opinion Could Become Issue in Christian Wilkins’s Case, Yahoo! Sports (Jul. 26, 2025) https://sports.yahoo.com/article/second-opinion-could-become-issue-135813399.html (explaining NFL’s Collective Bargaining Agreement and terms present in NFL contracts and how Wilkins is entitled to second medical opinion).

[7] See Scott Saloman, Explaining the NFL Grievance Process for Christian Wilkins, Raiders, Sports Illustrated (Jul. 29, 2025) https://www.si.com/nfl/raiders/las-vegas-pete-carroll-john-spytek-christian-wilkins (stating how NFLPA filed a grievance due to Raiders voiding Wilkins’ $32.5 million).

[8] See Yosef, supra note 1 (indicating how much of Wilkins’ guaranteed compensation has already been paid).

[9] See id. (demonstrating what combined payments constitutes Wilkins’ guaranteed compensation).

[10] See id. (illustrating individual components of Wilkins’ remaining guaranteed compensation).

[11] See Yosef, supra note 1 (explaining difference between injury and noninjury grievances that can be filed to challenge against NFL).

[12] See id. (discussing Wilkins’s injury leading to his dispute with Raiders, highlighting different rehabilitation courses); see Jones Fracture, Cleveland Clinic, https://my.clevelandclinic.org/health/diseases/22239-jones-fracture (last visited Sept. 27, 2025) (explaining Jones fractures as type of broken bone occurring in fifth metatarsal bones where pinkie toes are connected to base of foot).

[13] See id. (noting what type of grievance was filed in Christian Wilkins’ case).

[14] See Saloman, supra note 7 (outlining time requirements for filing grievances against NFL).

[15] See Deubert, supra note 3 (explaining purpose of guaranteed money in NFL contracts).

[16] See Baker & Finkel, supra note 6 (listing and describing what types of guarantees can be made in NFL contract).

[17] See id. (referencing relevant type of guarantee in Wilkins’ case and why Raiders’ termination decision may violate this type of guarantee).

[18] See id. (detailing Wilkins’s type of injury that ultimately ended with his release); see Jones Fracture, supra note 12 (indicating that common cause of Jones fractures is sports-related injury).

[19] See Las Vegas Raiders (@Raiders), X, (Jul. 24, 2025, at 7:55 ET), https://x.com/Raiders/status/1948532485379555704 (describing Raiders’ statement regarding why Wilkins was released, stating “[t]his franchise has a Commitment to Excellence on and off the field. With no clear path or plan for future return to play from Christian, this transaction is necessary for the entire organization to move forward and prepare for the new season.”).

[20] See id. (showcasing how Raiders seemingly intended to get out of their obligation to pay Wilkins’ remaining guaranteed money under his contract).

[21] See Baker & Finkel, supra note 6 (warning of guaranteed money intricacies in contracts and how important skilled legal counsel is in these high-stakes contracts, which are “subject to interpretation, litigation, and ‘loopholes’”).

[22] See id. (asserting Wilkins’ grievance argument seeking enforcement of his guaranteed money payouts from his contract).

[23] See id. (detailing that grievance will be followed by arbitration hearing, drawing on past events with Antonio Brown and then-Oakland Raiders in 2019).

[24] See Yosef, supra note 1 (referencing specific provisions in Wilkins’ contract that will make it hard for Raiders to prevail in this conflict).

[25] See Florio, supra note 6 (framing Wilkins’ grievance dispute as issue of whether Raiders’ medical recommendation conflicted with Wilkins’ right of autonomy under NFL’s Collective Bargaining Agreement).

[26] See NFL Collective Bargaining Agreement, NFLPA 219 (March 15, 2020), https://nflpaweb.blob.core.windows.net/website/PDFs/CBA/March-15-2020-NFL-NFLPA-Collective-Bargaining-Agreement-Final-Executed-Copy.pdf (outlining Collective Bargaining Agreement’s permission that NFL players may seek secondary opinions regarding treatment after suffering injury or diagnosis).

[27] See id. (noting CBA provision’s restrictions).

[28] See id. (illustrating Wilkins’ contractual safeguards allowing him to exercise medical autonomy).

[29] See Joel Corry, Agent’s Take: Fallout from Controversial Christian Wilkins Release and How Raiders Could Pay in the End, CBS Sports (Jul. 31, 2025), https://www.cbssports.com/nfl/news/agents-take-fallout-from-controversial-christian-wilkins-release-and-how-raiders-could-pay-in-the-end/ (referencing that Raiders medical staff determined that Wilkins needed additional foot surgery before organized team activities, which Wilkins declined, leading the Raiders to void remaining $32.25 million of Wilkins salary guarantees); see Image posted by Sports After Dark (@sportsafterdark), Instagram, The Raiders have released DT Christian Wilkins with the designation of terminated vested veteran. (Jul. 24, 2025), https://www.instagram.com/sportsafterdark/p/DMg0pFTPtw7/ (citing ESPN’s Adam Schefter stating “Christian Wilkins decided to decline multiple medical examinations/opinions from doctors & opted to rehab his foot through fracture surgery without having any second opinions”).

[30] See Corry, supra note 29 (highlighting how Raiders may frame their argument under paragraph eight of NFL Player Contracts, which states that players must maintain their physical condition to satisfaction of team doctors as well as make full and complete disclosures and good faith responses to team doctors).

[31] See id. (emphasizing how Coach’s comments may undermine Raiders’ argument that Wilkins violated his contract).

[32] See Baker & Finkel, supra note 6 (reiterating that “guarantees” in high-stake contracts, such as Wilkins, are subject to interpretation and “loopholes”).

[33] See Corry, supra note 29 (noting that “fully guaranteed” is misleading term in NFL contracts, such that Raiders would be trying to use “loophole” of unsatisfactory physical condition to avoid Wilkins skill, injury, and salary cap guarantees); see Deubert, supra note 3 (stressing that relevant CBA provision is understood to provide players with the ultimate right to choose their own treatment path, consistent with principle of autonomy).

[34] See Guzik, supra note 5 (referring to Christian Wilkins’ release over medical treatment dispute raises ethical questions about medical autonomy within NFL).

[35] See Deubert, supra note 3 (detailing bioethics principle and how it applies to Wilkins’ case).

[36] See Guzik, supra note 5 (explaining how Raiders’ decision acts as restraint on player autonomy).

[37] See id. (reintroducing CBA provision entitling NFL players, such as Christian Wilkins, to seek alternative medical advice which seeks to protect player autonomy).

[38] See Deubert, supra note 3 (illustrating that players should be free to make informed medical decisions rather than being compelled to follow team-prescribed treatment plans).

[39] See Guzik, supra note 5 (highlighting that Wilkins’ was within his rights afforded to him under CBA, and that Raiders’ decision could be seen as running afoul of player autonomy principles).

[40] See Deubert, supra note 3 (demonstrating how financial penalties tied to medical choices may undermine players’ rights to self-determined care).

[41] See Guzik, supra note 5 (noting that coercing players into complying with team medical advice by threatening punishment can set harmful precedent).