Len Bias played basketball at the University of Maryland in the mid-1980s. He was an outstanding player and was projected to be a top NBA draft selection. On June 17, 1986, the Boston Celtics drafted him into the NBA. Two days later, he was found dead in his dorm room from a cocaine overdose. Prior to his death, he had instructed his agent, Advantage International, Inc., to take out a $1 million life insurance policy. The policy was not issued prior to his death. Bias’ estate sued Advantage for failing to take out the policy.

1. What duties has Advantage allegedly breached, if any?

2. What do you think the court’s decision was? See Bias v. Advantage International, Inc. 905 F.2d 1558 (D.C. Cir. 1990).