Sunday, November 10, 2013

Law v. National Collegiate Athletic Association case brief

Law v. National Collegiate Athletic Association case brief summary
134 F.3d 1010 (1998)


CASE SYNOPSIS
The United States District Court for the District of Kansas granted summary judgment on the issue of antitrust liability to plaintiff coaches who challenged a rule promulgated by defendant association that limited the annual compensation of certain coaches. The district court also issued a permanent injunction restraining the association from promulgating rules embodying similar compensation restrictions. The association appealed.

CASE FACTS
The coaches challenged the association's rule under § 1 of the Sherman Antitrust Act, 15 U.S.C.S. § 1, alleging that the rule was an unlawful contract, combination, or conspiracy in restraint of trade. The district court applied the rule of reason standard to its analysis of the rule. On appeal, the coaches urged the court to apply a per se analysis to the rule. The appellate court rejected the suggestion, opting to also apply the rule of reason. The association argued that the district court erred by failing to define the relevant market and by failing to find that the association possessed power in that market, and the association offered three justifications for the salary limits contained in the challenged rule.

DISCUSSION
The appellate court held that the district court was not required to resolve fact issues pertaining to the definition of the relevant market to support its decision that the rule was a naked price restraint, and found that the association's suggested justifications were insufficient to withstand a motion for summary judgment. Finally, the appellate court rejected the association's suggestion that it adopt a wait and see approach to give the rule time to succeed.

CONCLUSION

The court affirmed the district court's order granting a permanent injunction based on its order granting summary judgment to the coaches on the issue of antitrust liability.

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