Thursday, November 7, 2013

Clarett v. National Football League case brief

Clarett v. National Football League case brief summary
369 F.3d 124 (2004)

Defendant, the National Football League (NFL), appealed from a summary judgment of the United States District Court for the Southern District of New York ordering plaintiff amateur football player eligible to enter 2004's NFL draft on the ground that the NFL's eligibility rules were an unreasonable restraint of trade in violation of § 1 of the Sherman Act, 15 U.S.C.S. § 1, and § 4 of the Clayton Act, 15 U.S.C.S. § 15.

The district court concluded that the NFL's eligibility rules violated the antitrust laws by requiring the player to wait at least three full football seasons after his high school graduation before entering the NFL draft. In reaching its conclusion, the district court held that the eligibility rules were not immune from antitrust scrutiny under the non-statutory labor exemption.


  • The appellate court disagreed. 
  • While the player argued that NFL clubs were horizontal competitors for the labor of professional football players and thus might not agree that a player would be hired only after three full football seasons had elapsed after that player's high school graduation, that characterization neglected that the labor market for NFL players was organized around a collective bargaining relationship that was provided for and promoted by federal law labor, and that the NFL clubs could act jointly in setting the terms and conditions of players' employment and the rules of the sport without risking antitrust liability. 
  • Thus, the federal labor law favoring and governing the collective bargaining process precluded the application of the antitrust laws to the NFL's eligibility rules.

The district court's judgment was reversed and the case was remanded with instructions to enter judgment in favor of the NFL. The district court's order designating the player eligible to enter the 2004 NFL draft was vacated.

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