CAS Case Digest · Verified against the full award text

CAS 2024/A/10638 & CAS 2024/A/10771 — Queens Park Rangers Football Club & Reginald Jacob Cannon v. Boavista Futebol Clube

"Cannon / QPR v. Boavista" · CAS held that Cannon had just cause to terminate his Boavista contract due to persistent late salary payments, reversing the FIFA DRC's finding of unjustified termination.

What happened in Cannon / QPR v. Boavista

Reginald Jacob Cannon, a US professional footballer, signed a five-year employment contract with Portuguese club Boavista FC in September 2020. Boavista paid 28 of 29 monthly salaries late — between 5 and 98 days after their due dates — prompting Cannon to issue three formal default notices (July 2021, March 2023, May 2023). After the May 2023 notice, Boavista wired payment on 29 May 2023, but funds only reached Cannon's US bank account on 1 June 2023, beyond the three-working-day deadline under the Portuguese Collective Bargaining Agreement (CBA). Cannon terminated the contract on 22 June 2023 and subsequently signed with QPR. Boavista filed a FIFA DRC claim; the DRC found no just cause and ordered Cannon to pay EUR 1,287,000 in compensation, with QPR jointly and severally liable. Both Cannon and QPR appealed to CAS. The CAS Panel reversed the DRC, finding just cause under Article 14 FIFA RSTP based on Boavista's persistent, severe breach of its primary obligation to pay salaries on time. The Panel awarded Cannon EUR 294,325 net compensation (mitigated compensation of EUR 187,000 plus additional compensation of EUR 107,325) plus 5% p.a. interest from 22 June 2023. The case matters because it confirms that persistent late salary payments — even where individual arrears are eventually settled — can cumulatively constitute just cause for termination, and that the Portuguese CBA's three-day notice period prevails over FIFA RSTP's fifteen-day period.

Procedural history of CAS 2024/A/10638

On 8 March 2024, Boavista lodged a claim before the FIFA Dispute Resolution Chamber (DRC) against Cannon and QPR. On 19 March 2024, Cannon filed a counterclaim. The FIFA DRC rendered its decision on 27 June 2024 (grounds communicated 10 July 2024), finding that Cannon terminated the contract without just cause because Boavista had remedied the payment default before termination. The DRC ordered Cannon to pay Boavista EUR 1,287,000 as compensation plus 5% p.a. interest from 22 June 2023, with QPR jointly and severally liable. It also ordered Boavista to pay Cannon EUR 45,000 and EUR 33,000 as outstanding remuneration. On 31 July 2024, both QPR (CAS 2024/A/10638) and Cannon (CAS 2024/A/10771) filed separate Statements of Appeal with CAS. The two proceedings were consolidated on 16 August 2024 pursuant to Article R52 of the CAS Code. A hearing was held in Lausanne on 2 April 2025.

Key holdings in CAS 2024/A/10638

• Boavista's persistent failure to pay Cannon's salaries on time — 28 of 29 payments made between 5 and 98 days late — constituted a severe breach of its primary contractual obligation sufficient to give Cannon just cause to terminate under Article 14(1) FIFA RSTP.
• The Portuguese CBA's three-working-day notice period prevails over the fifteen-day period in Article 14bis(1) FIFA RSTP by virtue of Article 14bis(3), which provides that validly negotiated collective bargaining agreements shall prevail.
• A player's failure to terminate earlier does not constitute acceptance of persistent late payments, and the club bears the risk of termination at the moment the player decides the breach is no longer tolerable.
• Where a player consents to mutual termination of his new contract, he fails to mitigate his losses, and the salary he would have received under that new contract must still be deducted when calculating compensation under Article 17(1)(ii) FIFA RSTP.
• The FIFA RSTP Interim Regulations (in force 1 January 2025) apply only to cases pending before the FIFA Football Tribunal and not to cases already on appeal before CAS, so QPR's automatic joint and several liability under the February 2024 FIFA RSTP governed the proceedings.

How the CAS panel reasoned

The Panel first resolved applicable law: the February 2024 FIFA RSTP governed as the claim was filed on 8 March 2024; the Portuguese CBA prevailed over Article 14bis paragraphs 1–2 by operation of Article 14bis(3), reducing the notice period from 15 to 3 days. The Panel dismissed the tax-withholding argument for lack of proof. On just cause, the Panel applied the standard from CAS 2006/A/1180 and CAS 2015/A/4046 & 4047: only a particularly severe breach — or persistent lesser breaches after warning — justifies immediate termination. It found that 28 of 29 late payments, delays of up to 98 days, three formal default notices, and Boavista's continued non-compliance after each notice collectively crossed that threshold. The Panel rejected Boavista's condonation argument under CBA Article 45, holding that the default notices themselves negated any inference of acceptance. On compensation, the Panel applied Article 17(1)(ii): residual contract value (EUR 1,062,000) minus QPR salary for the corresponding period (GBP 730,000 = EUR 875,000) yielded mitigated compensation of EUR 187,000, plus three average monthly salaries (EUR 35,775 × 3 = EUR 107,325) as additional compensation, totalling EUR 294,325. The stay request was denied because future FIFA rule changes would not apply retroactively and EU law could be applied directly if warranted. The Diarra Case analysis was rendered moot by the just-cause finding.

Why Cannon / QPR v. Boavista matters in CAS jurisprudence

This award reinforces that cumulative, persistent late salary payments — even when individual arrears are eventually cured — can constitute just cause for termination under Article 14 FIFA RSTP without requiring the player to invoke Article 14bis. It authoritatively confirms that a validly negotiated domestic CBA (here, the Portuguese CBA's three-day notice period) prevails over the FIFA RSTP's fifteen-day period under Article 14bis(3). The Panel also clarifies that the FIFA RSTP Interim Regulations (January 2025) do not apply retroactively to CAS appeals of pre-existing DRC decisions, preserving the automatic joint-and-several liability framework for cases governed by the February 2024 RSTP.

Cases cited in this award

CAS 2015/A/4046 & 4047 CAS 2006/A/1180 CAS 2020/A/6796 CAS 2020/A/6727 CAS 2019/A/6594 CAS 2022/A/9016

Frequently asked questions about Cannon / QPR v. Boavista

Did Reginald Cannon have just cause to terminate his Boavista contract despite Boavista eventually paying the overdue salaries?

Yes. The CAS Panel found just cause under Article 14(1) FIFA RSTP based on the cumulative pattern of persistent late payments: 28 of 29 salary payments were made between 5 and 98 days late, and Cannon had issued three formal default notices over nearly three years. The Panel held that a player's failure to terminate earlier does not constitute acceptance of the breach, and that Boavista's eventual payment of individual arrears did not cure the fundamental breakdown of trust caused by its persistent conduct.

Why did the three-day CBA notice period apply instead of the fifteen-day period in Article 14bis FIFA RSTP?

Article 14bis(3) FIFA RSTP expressly provides that validly negotiated collective bargaining agreements at domestic level shall prevail over the principles in paragraphs 1 and 2 of that article. The Portuguese CBA, negotiated between the Portuguese Professional Football League and the Professional Football Players' National Union, stipulates only a three-working-day notice period. The Panel also noted that both parties had operated under the understanding that the three-day period applied throughout their contractual relationship.

How was Cannon's compensation of EUR 294,325 calculated after CAS found just cause?

The Panel applied Article 17(1)(ii) FIFA RSTP. The residual value of the Boavista contract was EUR 1,062,000 (comprising pro-rata June 2023 salary of EUR 12,000, EUR 500,000 for 2023/2024, and EUR 550,000 for 2024/2025). From this, the Panel deducted EUR 875,000 (equivalent of GBP 730,000 — Cannon's QPR salary for the corresponding period), yielding mitigated compensation of EUR 187,000. Although Cannon and QPR mutually terminated the QPR contract in August 2024, the Panel treated that as a failure to mitigate and still deducted the full QPR salary. Three average monthly salaries (EUR 35,775 × 3 = EUR 107,325) were added as additional compensation, giving a total of EUR 294,325.

Did the CJEU's Diarra ruling or the FIFA RSTP Interim Regulations (January 2025) affect QPR's liability in this case?

No. The Panel rejected QPR's request for a stay pending FIFA rule changes, reasoning that the February 2024 FIFA RSTP governed the case and future amendments would not apply retroactively. The Interim Regulations explicitly apply only to cases pending before the FIFA Football Tribunal, not to CAS appeals of already-decided DRC cases. Ultimately, the Diarra analysis was rendered moot because the Panel found just cause for termination, meaning no compensation was owed to Boavista and QPR's joint and several liability was annulled on that basis.

Topics: Art. 17 RSTP & contract termination at CAS

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