Philadelphia World Hockey Club v. Philadelphia Hockey Club case brief

Philadelphia World Hockey Club v. Philadelphia Hockey Club case brief summary
351 F.Supp. 462 (1972)

CASE SYNOPSIS

Plaintiff, a world hockey league, member clubs, and teams, filed a motion for a preliminary injunction pursuant to 15 U.S.C.S. § 26 against defendant, a national hockey league, to prevent its monopolistic position as the sole supplier of major league hockey competition. The world hockey league alleged antitrust law violations under § 2 of the Sherman Act.

CASE FACTS
The national league had been the only major hockey league until the birth of the world league and held a monopolistic position as the sole supplier of major league hockey competition.

DISCUSSION

• The court granted the world league's motion for injunctive relief because it established the necessary irreparable harm. 
• The national league attempted to invoke the labor exemptions from the Sherman Act authorized by §§ 6 and 20 of the Clayton Act, specifically at 15 U.S.C.S. § 17 and 29 U.S.C.S. § 52. 
• The court concluded that due to its monopolistic actions, the national league could not invoke the labor exemptions under the Clayton Act and was subject to prosecution under the Sherman Act. 
• The national league's reserve clause was not the subject of any serious arm's length collective bargaining. 
• Even if there had been substantial bargaining, the national league was not shielded from liability in an action by outside competitors who sought access to players under the national league's control. 
• The court held that preliminary injunctive relief pursuant to 15 U.S.C.S. § 26 was warranted due to the national league's power to overwhelmingly control the relevant market.

CONCLUSION

The court granted the world league's motion for preliminary injunctive relief against the national league. The court held that the national league was subject to prosecution under the Sherman Act.

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