CAS Case Digest · Verified against the full award text

CAS 2025/A/11494 — Yukatel Adana Demirspor A.S. v. John Steven Mendoza Valencia & Club León FC

"Adana Demirspor v. Mendoza" · CAS confirmed a Colombian player had just cause under Art. 14 FIFA RSTP to terminate his contract with a Turkish club due to persistent, cumulative salary non-payment.

What happened in Adana Demirspor v. Mendoza

Colombian professional footballer John Steven Mendoza Valencia signed a contract with Turkish club Yukatel Adana Demirspor on 6 February 2024, valid until 30 June 2025, providing EUR 450,000 net for 2023/24 and EUR 900,000 net for 2024/25. From the outset, Adana failed to pay salaries on time: the February 2024 salary was paid 17 days late; March and April 2024 salaries were paid only after the Player issued a formal Default Notice on 7 June 2024; and the May 2024 salary (EUR 90,000) and the EUR 100,000 Guaranteed Bonus remained entirely unpaid at termination. On 5 July 2024, the Player terminated the contract and signed with Mexican club León FC on 8 July 2024. Adana withheld the ITC, and the Player filed a claim before the FIFA DRC, which on 27 March 2025 found just cause and ordered Adana to pay EUR 272,508 net in outstanding remuneration plus EUR 404,605 net in compensation. Adana appealed to CAS. The Panel dismissed the appeal, confirming that while Art. 14bis RSTP was inapplicable (two full monthly salaries were not overdue at the time of the Default Notice), the cumulative pattern of persistent late and non-payment constituted just cause under Art. 14 para. 1 FIFA RSTP. The case matters because it clarifies that Art. 14 RSTP can ground just cause even where Art. 14bis thresholds are not technically met, provided the cumulative breach is sufficiently serious.

Procedural history of CAS 2025/A/11494

On 19 August 2024, the Player filed a claim before the FIFA Football Tribunal Dispute Resolution Chamber (ref. FPSD-15650), seeking confirmation of just cause termination, outstanding remuneration, compensation, and a registration ban on Adana. Adana filed a counterclaim alleging termination without just cause and seeking EUR 2,245,000 jointly from the Player and León. On 27 March 2025, the FIFA DRC partially accepted the Player's claim: it found just cause, ordered Adana to pay EUR 272,508 net in outstanding remuneration (with 5% interest) and EUR 404,605 net in compensation (with 5% interest from 6 July 2024), and rejected Adana's counterclaim. On 5 June 2025, Adana filed a Statement of Appeal at CAS under Arts. R47 and R48 of the CAS Code, seeking annulment of the FIFA DRC decision, a finding of termination without just cause, and EUR 2,245,000 in compensation jointly from the Player and León. A hearing took place on 6 February 2026 at CAS headquarters in Lausanne.

Key holdings in CAS 2025/A/11494

• Art. 14bis para. 1 FIFA RSTP was inapplicable because, at the date of the Player's Default Notice (received 8 June 2024), two full monthly salary amounts were not yet due under the Contract.
• A cumulative pattern of persistent late and non-payment of salary obligations, even where no single breach individually suffices, can constitute just cause for unilateral termination under Art. 14 para. 1 FIFA RSTP.
• A formal Default Notice, even if it overstates the amounts due and references only Art. 14bis rather than Art. 14, can constitute adequate warning to the club for purposes of the ultima ratio requirement under Art. 14 para. 1 FIFA RSTP.
• A player's refusal to attend pre-season training, in circumstances where the club has persistently failed to pay salary and the contractual relationship has fundamentally broken down, may be treated as a last-resort measure rather than a breach of contract.
• In the absence of any evidence of prior contact or inducement, the mere fact that a player signed with a new club three days after termination is insufficient to establish joint and several liability of the new club under Art. 17.2 FIFA RSTP.

How the CAS panel reasoned

The Panel first disposed of Art. 14bis, accepting the parties' agreed position that two full monthly salaries were not overdue at the time of the Default Notice. Turning to Art. 14 para. 1, the Panel applied the 'comfortable satisfaction' standard and conducted a chronological payment analysis using Art. 87(1) SCO to allocate payments to the earliest outstanding debts. It found that not a single payment had been made fully on time across the entire contract: the February salary was 17 days late; March and April salaries were paid weeks late only after the Default Notice; and the May salary and Guaranteed Bonus remained entirely unpaid at termination. The Club's only explanation — that it was a 'small club' — was dismissed as entirely unsatisfactory given its knowingly assumed obligations. The Panel held that while each individual breach might not alone justify termination, the cumulative effect over six months did. On ultima ratio, the Panel found the Default Notice, despite its inaccuracies, constituted adequate warning. Post-notice, the Club still failed to pay the May salary and Guaranteed Bonus, confirming irreparable breakdown of trust. The Player's non-attendance at training was treated as a retention-of-services measure, not a breach, partly because the Club itself failed to provide contractually required flight tickets. León's alleged inducement was dismissed for lack of any corroborating evidence beyond the three-day gap between termination and signing.

Why Adana Demirspor v. Mendoza matters in CAS jurisprudence

This award clarifies the relationship between Art. 14 and Art. 14bis FIFA RSTP under the January 2025 edition, confirming that a player may establish just cause under the broader Art. 14 even where the technical two-salary threshold of Art. 14bis is not met. It establishes that cumulative, persistent late payment — with not a single on-time payment across a six-month contract — can independently ground just cause, and that an imprecise default notice still satisfies the ultima ratio warning requirement. The award also applies the post-Diarra burden-of-proof framework to reject inducement claims based solely on timing.

Cases cited in this award

CAS 2008/A/1519-1520 CAS 2019/A/6171 & CAS 2019/A/6175 CAS 2006/A/1180 CAS 2022/A/8963 CAS 2013/A/3091, 3092 & 3093 CAS 2014/A/3757

Frequently asked questions about Adana Demirspor v. Mendoza

Did Adana Demirspor lose the Mendoza CAS case because it failed to pay two monthly salaries?

Not solely on that basis. The Panel agreed that Art. 14bis para. 1 FIFA RSTP did not apply because two full monthly salaries were not yet overdue at the date of the Default Notice. However, the Panel found just cause under the broader Art. 14 para. 1 FIFA RSTP based on the cumulative pattern of persistent late and non-payment across the entire contract, including the May 2024 salary and EUR 100,000 Guaranteed Bonus that remained entirely unpaid at termination on 5 July 2024.

Can a player's default notice that overstates the amounts owed still satisfy the ultima ratio warning requirement under Art. 14 FIFA RSTP?

Yes, according to this award. The Panel acknowledged that the Player's Default Notice of 7 June 2024 incorrectly claimed EUR 460,000 when only EUR 147,008 was strictly overdue at that date, and that it referenced Art. 14bis rather than Art. 14. Nevertheless, the Panel held that the notice constituted adequate warning because, from the perspective of a reasonable addressee, it clearly signalled the Player's loss of confidence and his insistence on timely payment, putting the Club on notice that further failures would be taken into account in any just cause assessment.

Was Club León FC held jointly liable for compensation in the Adana Demirspor v. Mendoza case?

No. The Panel found that Adana provided no evidence beyond the three-day gap between the Player's termination on 5 July 2024 and his signing with León on 8 July 2024 to substantiate inducement. Under the post-Diarra framework incorporated into the January 2025 FIFA RSTP, the automatic presumption of inducement by the new club has been eliminated, and the burden of proving active inducement rests on the requesting party. Adana failed to discharge that burden, so León's joint and several liability was rejected entirely.

How did the CAS panel calculate the outstanding amounts owed to Mendoza by Adana Demirspor?

The Panel applied Art. 87(1) SCO, allocating payments to the earliest outstanding debt in the absence of a specific designation by the debtor. On this basis: the February 2024 salary (EUR 90,000) was paid 17 days late on 4 March 2024; the March 2024 salary was partly offset by EUR 31,492 under the Declaration on 25 May 2024 and the balance of EUR 58,508 paid from the EUR 60,000 payment on 21 June 2024; the April 2024 salary was paid from the remainder of the 21 June payment (EUR 1,492) and EUR 88,508 of the EUR 96,000 payment on 24 June 2024. The May 2024 salary and the EUR 100,000 Guaranteed Bonus remained entirely unpaid at termination, totalling EUR 272,508 net in outstanding remuneration as confirmed by the FIFA DRC.

Topics: Art. 17 RSTP & contract termination at CAS

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