Thursday, November 7, 2013

Chicago Professional Sports, Ltd. & WGN v. NBA (Bulls I) case brief

Chicago Professional Sports, Ltd. & WGN v. NBA (Bulls I) case brief summary
961 F.2d 667 (1992)


CASE SYNOPSIS
Defendant, a professional basketball association, appealed a decision from the United States District Court for the Northern District of Illinois, Eastern Division, to enjoin defendant from enforcing the 20-game limit for broadcasting basketball games imposed on plaintiff team and plaintiff broadcasting company.

CASE FACTS
Plaintiff broadcasting company was a Chicago broadcasting company that televised sports. Plaintiff team was a professional basketball team. When defendant, a professional basketball association, restricted all teams in the association to a 20-game limit for telecasts, plaintiffs objected.

DISCUSSION
  • The court held that under the rule of reason the plaintiffs would be injured by defendant's actions and that, therefore, defendant was enjoined from enforcing the 20-game limit. 
  • The court found that the Sports Broadcasting Act (Act), 15 U.S.C.S. § 1291, did not exempt defendant's actions from an antitrust violation. 
  • The court held that the Act dealt with transfers made, not transfers forbidden, which was the type of restriction the defendant created. 
  • The court concluded that plaintiffs would suffer injury-in-fact unless defendant was enjoined.

CONCLUSION
The court affirmed and held that the under the rule of reason, plaintiff team and plaintiff broadcasting company would suffer injury-in-fact with the 20-game restriction, and the court concluded that it would not overturn the decision of the lower court to enjoin defendant.



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