Fraser v. Major League Soccer case brief

Fraser v. Major League Soccer case brief summary
284 F.3d 47 (2002)

CASE SYNOPSIS

Plaintiff soccer players sought review of a decision from the United States District Court for the District of Massachusetts, which granted summary judgment to defendants, soccer association, operator/investors, and soccer federation, on plaintiffs' 15 U.S.C.S. §§ 1 and 18 claims, and entered judgment on a special verdict in favor of defendants on plaintiffs' 15 U.S.C.S. § 2 claim.

DISCUSSION

• The court affirmed the summary judgment on the 15 U.S.C.S. § 1 claim. 
• The court found that the effects of defendants' arrangement simply were too uncertain to warrant application of the per se rule. 
• Moreover, even if the § 1 claim had not been dismissed on summary judgment, the jury still would have found in favor of defendants on the grounds that the market alleged in the complaint had not been proved. 
• The court also affirmed the judgment for defendants on the 15 U.S.C.S. § 2 claim, as plaintiffs had failed to establish the relevant market as alleged. 
• Furthermore, plaintiffs failed to show the requisite prejudice resulting from alleged errors in certain jury instructions and certain evidentiary rulings. 
• The court concluded by affirming the dismissal through summary judgment of plaintiffs' 15 U.S.C.S. § 18 claims. 
• The court agreed with the district court that there was no liability under the statute where the formation of the soccer association did not involve the acquisition or merger of existing business enterprises, but rather the formation of an entirely new entity which itself represented the creation of an entirely new market.

CONCLUSION
The court affirmed the judgments in favor of defendants on plaintiffs' claims under the Sherman and Clayton Acts.



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