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There was a time when the Bulls fueled the fire of NBA salary cap disputes

Salary cap circumvention disputes didn't start in the modern NBA.
ByMorris Bankston
Jan 11, 2024; Chicago, IL, USA; Horace Grant attends inaugural Ring of Honor gala at United Center. Mandatory Credit: Kamil Krzaczynski-USA TODAY Sports
Jan 11, 2024; Chicago, IL, USA; Horace Grant attends inaugural Ring of Honor gala at United Center. Mandatory Credit: Kamil Krzaczynski-USA TODAY Sports | USA TODAY Sports via Reuters Connect

Between Oct 1993 and Mar 1995 is a stretch of time that most Bulls fans who lived through this period are more than happy to forget.  The first Michael Jordan retirement, Hue Hollins officiating in game five of the Bulls' 1994 NBA Playoffs semifinal series against the hated New York Knicks.

Not to be outdone by any of those moments, the Bulls’ first three-peat stalwart at the power forward position, Horace Grant, fell into a contentious relationship with Bulls ownership and management over price negotiations on Grant’s next NBA contract going into the 1993-94 NBA season.

Grant weaponized his contract-year motivation into the finest individual NBA season of his career: 1994 NBA All-Star Game selection, 1993-94 NBA All-Defensive Second Team Selection, regular-season averages of 15.1 points per game, 11.0 rebounds per game, 1.1 steals per game, and 1.2 blocks per game.

The internal Bulls organizational conflict and the competitive drive surrounding Grant’s lone NBA All-Star season came to a head in the 1994 NBA offseason when Grant entered unrestricted free agency and signed a new contract with the Orlando Magic.  

Grant’s deal with the Magic was far from simple.  Instead, Grant’s new NBA pact with the Magic devolved into chaos, all too relevant to the 2026 NBA offseason, when Grant quickly became embroiled in NBA and legal battles over salary cap circumvention after his Magic free-agency deal became public knowledge.  

Bird Rights Gone Wrong

Grant’s original Orlando Magic deal was structured to pay the then-three-time NBA champion $22.3 million over six years, however, the contract also included an opt-out clause after the first year of the contract, allowing Grant to re-enter unrestricted free agency after his first season playing for the Magic.

In 1995, the NBA/NBPA collective bargaining agreement’s language carried simplified requirements for applying (subscription required) Bird Rights exceptions to player salaries. 

If an NBA franchise rostered a player for at least one year, Bird Rights could be applied to pay the player any amount to retain that player on a new NBA contract, even if it exceeded the salary cap.

The NBA invalidated Grant’s initial contract with the Magic on the grounds of a violation of NBA salary cap rules, and then took the franchise to Federal court to rule on the contract dispute.  The court issued a ruling (subscription required) that Grant’s initial Magic contract could violate the NBA salary cap, and subsequently Grant and the Magic agreed on a revised contract with a two-year opt-out clause.

Horace Grant’s contribution to NBA history

Grant’s disgruntled free-agency departure from the Bulls and the consequential salary cap circumvention battle that emerged from his contract negotiations with the Magic became a prominently framed, tense conflict between the NBA and NBPA over the existence of Bird Rights in the NBA/NBPA collective bargaining agreement. The topic that proved to be one of the primary reasons that triggered the infamous 1998-99 NBA Lockout.

One key resolution that emerged from the negotiations that ended the 1998-99 NBA Lockout was the creation of the three-tier structure of Bird Rights salary cap exceptions, which are still used on NBA contracts as of 2026.

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