Mackey v. National Football League (Part I) case brief summary
543 F.2d 606 (1976)
CASE FACTS
Plaintiff professional football players sued defendant football league and commissioner alleging that league rule requiring a team acquiring a player whose contract had expired to pay the player's former team compensation violated the Sherman Act, 15 U.S.C.S. § 1. The trial court granted plaintiffs judgment and enjoined enforcement of the rule. On appeal, defendant's argued that the non-statutory labor exemption immunized defendants from antitrust liability.
DISCUSSION
The court affirmed, holding that the non-statutory labor exemption did not apply because while the rule affected only the parties to the collective bargaining agreement, and the agreement concerned a mandatory subject of collective bargaining, it was not the product of a bona fide arm's-length bargaining. The court held that the rule was not per-se illegal under the Sherman Act, but found it illegal under the Rule of Reason because the restraint was not justified by a legitimate business purpose and was more restrictive than necessary.
CONCLUSION
Court affirmed judgment for plaintiff football players against defendants league and commissioner in suit for Sherman Act violation for league regulation requiring team acquiring player whose contract expired to pay former team because non-statutory labor exemption did not provide immunity to defendants and regulation was illegal under Rule of Reason.
Suggested Study Aid For Sports Law
543 F.2d 606 (1976)
CASE SYNOPSIS
Defendant football league and defendant
commissioner appealed a judgment in favor of plaintiff professional
football players of the United States District Court for the District
of Minnesota holding that the league rule requiring the team that
acquired a player whose contract expired to pay the former team
violated the Sherman Act, 15 U.S.C.S. § 1.CASE FACTS
Plaintiff professional football players sued defendant football league and commissioner alleging that league rule requiring a team acquiring a player whose contract had expired to pay the player's former team compensation violated the Sherman Act, 15 U.S.C.S. § 1. The trial court granted plaintiffs judgment and enjoined enforcement of the rule. On appeal, defendant's argued that the non-statutory labor exemption immunized defendants from antitrust liability.
DISCUSSION
The court affirmed, holding that the non-statutory labor exemption did not apply because while the rule affected only the parties to the collective bargaining agreement, and the agreement concerned a mandatory subject of collective bargaining, it was not the product of a bona fide arm's-length bargaining. The court held that the rule was not per-se illegal under the Sherman Act, but found it illegal under the Rule of Reason because the restraint was not justified by a legitimate business purpose and was more restrictive than necessary.
CONCLUSION
Court affirmed judgment for plaintiff football players against defendants league and commissioner in suit for Sherman Act violation for league regulation requiring team acquiring player whose contract expired to pay former team because non-statutory labor exemption did not provide immunity to defendants and regulation was illegal under Rule of Reason.
Suggested Study Aid For Sports Law
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