Thursday, November 7, 2013

Chicago Professional Sports Ltd. Partnership & WGN v. National Basketball Association case brief

Chicago Professional Sports Ltd. Partnership & WGN v. National Basketball Association case brief summary
95 F.3d 593 (1996)

Appeal from a judgment of the United States District Court for the Northern District of Illinois, which invalidated restrictive licensing fees defendant basketball association imposed for plaintiff television station to purchase broadcast rights to plaintiff basketball team's games.

Plaintiff was a member of defendant's sports league that sought to sell broadcast rights to plaintiff television station, while defendant sought to restrict broadcast rights and impose additional fees. Plaintiffs claimed this action violated antitrust laws, while defendant argued it should be treated as a single firm under antitrust laws, possessing options to restrict licensing rights. However, the trial court invalidated the restrictive fees and held defendant could not be considered a single firm because defendant and its member teams did not have a complete unity of interest.

  • The court held that this was erroneous reasoning because complete unity of interest was not a legal requirement of a single entity operation under antitrust law. 
  • The court refused to determine defendant's status, holding its power was only to review a district court's determination for its propriety. 
  • However, the court held defendant's integration of operations warranted full application of the Rule of Reason inquiry on remand.


Judgment vacated and remanded due to the trial court's erroneous reasoning in determining defendant's status under antitrust law.

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