Banks v. NCAA case brief

Banks v. NCAA case brief summary
977 F.2d 1081 (1992)

CASE SYNOPSIS

Plaintiff appealed the dismissal of his claim by the United States District Court for the Northern District of Indiana, South Bend Division, contending that the district court erred in finding that he had failed to state a claim upon which relief could have been granted under 15 U.S.C.S. § 1.

CASE FACTS
Plaintiff filed suit, contending that defendant's no-draft and no-agent rules, which terminated an athlete's eligibility to participate in college sports, constituted an illegal restraint on trade in violation of 15 U.S.C.S. § 1. Plaintiff appealed the district court's dismissal for failure to state a claim.

DISCUSSION

• In affirming, the court concluded that plaintiff's claim was moot; plaintiff had no standing to bring the suit as his ineligibility to participate in college sports prevented him from having a personal stake in whether defendant continued to enforce its rules. 
• Further, where plaintiff failed to allege the rules' anti-competitive effect on an identifiable market, plaintiff's claim failed to state a claim upon which relief could be granted under Fed. R. Civ. P. 12(b)(6). 
• The Sherman Act was designed to rectify injury caused by diminished competition. Plaintiff failed to allege such an anticompetitive effect; thus, he failed to state a cause of action.

CONCLUSION

The court affirmed the order of dismissal as plaintiff's ineligibility to participate in college sports deprived him of standing. Further, dismissal was proper as plaintiff failed to establish that defendant's no-draft and no-agent rules had an anti-competitive effect; plaintiff thus failed to state a cause of action under the Sherman Act.

Suggested Study Aid For Sports Law