According to a brief submitted on behalf of Flores, Steve Wilks (53) and Ray Horton (62), the NFL's arbitration procedure bears no resemblance to a neutral judicial forum and fails to comport with basic principles of fairness.

It adds that "nobody could credibly argue" that Commissioner Roger Goodell can be a neutral arbitrator when it comes to ruling on claims that involve teams which pay him and given the NFL has already said the lawsuit is "without merit".

"If the court compels arbitration, scores of employers following this case, and those who learn of it, will undoubtedly change their arbitration clauses to permit the appointment of an obviously biased decision maker," the brief said.

Flores, who is Black, was fired by Miami in January after back-to-back seasons with winning records and sued the NFL and its teams in February alleging discrimination against Black candidates for top-level coaching and management jobs.

Former Arizona Cardinals head coach Wilks and longtime assistant coach Horton joined as plaintiffs in the proposed class action in April.

The case by Flores, who has been hired by the Pittsburgh Steelers as a senior defensive assistant and linebacker coach, has highlighted a lack of diversity in the coaching ranks of the NFL, which has long condemned racism.