Los Angeles Memorial Coliseum Comm’n v. NFL (Raiders I) case brief

Los Angeles Memorial Coliseum Comm’n v. NFL (Raiders I) case brief summary

726 F.2d 1381 (1984)

CASE SYNOPSIS

Defendants, football league, member clubs, and interested parties, appealed a decision of the United States District Court for the Central District of California permanently enjoining defendants, on anti-trust grounds, from interfering with the transfer of plaintiff owner's football franchise to plaintiff commission's stadium.

CASE FACTS

The commission sued the football league and the member clubs alleging that the league's constitution contained a rule restraining trade in violation of § 1 of the Sherman Act, 15 U.S.C.S. § 1. The rule, which required three-quarters approval by the members before any single member could move into another's home territory, prevented the owner's football franchise from moving to the commission's stadium. After the jury returned a verdict against defendants, the trial court permanently enjoined defendants from interfering with the move.

DISCUSSION
The court affirmed, rejecting arguments that the league was a single entity incapable of conspiring to restrain trade, because the members were sufficiently independent and competitive with one another to warrant rule of reason scrutiny. Further, the jury could have determined from the evidence that the rule harmed competition among the members to such an extent that any benefits to the league as a whole were outweighed.

CONCLUSION

The court affirmed because the member clubs were sufficiently independent and competitive with one another to warrant rule of reason scrutiny, and the jury could have determined from the evidence that the rule harmed competition among the member clubs to such an extent that any benefits to the football league were outweighed.

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