The NFL Players Association legal department issued a memo to agents about the city of Cleveland non-resident or so-called "jock tax" following legal tax victories for former NFL players Hunter Hillenmeyer and Jeff Saturday. Here's the full memo: To:      Contract Advisors From:  NFLPA Legal Department Re:      City of Cleveland Non-Resident Tax Date:   May 4, 2015 Last week the Ohio Supreme Court issued decisions in two important tax cases involving former NFL players -- Hunter Hillenmeyer and Jeff Saturday.  These cases challenged the City of Cleveland’s methods for taxing non-resident professional athletes,  They were funded and advanced by the NFLPA on behalf of the players, since the issues in the cases impact numerous NFL players each year. In both cases, the Ohio Supreme Court ruled in favor of the players. Hillenmeyer challenged the City of Cleveland’s use of their  so-called “games played” method of allocating the income of  non-resident professional athletes.  Use of the “games played” method resulted in Cleveland allocating to itself a far greater percentage of an athlete’s income than the more equitable “duty days” method, which is based on the number of working days an athlete spends in a taxing jurisdiction divided by the total number of working days in a season.  In the case of Hillenmeyer, for example, although he was only present in Cleveland for two days in each of the relevant tax years at issue, Cleveland allocated 5% of  Hillenmeyer’s income in each year to Cleveland.  In its decision, the Court agreed with Hillenmeyer and ruled that the “games played” formula violated the Due Process Clause of the U.S. Constitution. Saturday’s case not only challenged Cleveland’s allocation of income on a  “games played” basis, but also challenged Cleveland’s right to tax Saturday when he never was present in the City of Cleveland during the tax year at issue.  Saturday was injured and did not travel to Cleveland when his team played the Browns.  Cleveland nevertheless assessed income tax against Saturday for the game.  The  Court ruled that Cleveland had no statutory basis for taxing Saturday since he never stepped foot in Cleveland. These decisions represent clear victories for professional athletes who are often unfairly targeted by local taxing authorities. Follow me on Twitter: @RavensInsider Aaron Wilson covers the Ravens for The Baltimore Sun