Sunday, November 10, 2013

National Hockey League Players Association v. Plymouth Whalers Hockey Club case brief

National Hockey League Players Association v. Plymouth Whalers Hockey Club case brief summary
419 F.3d 462 (2005)

Plaintiffs, a national hockey association and players, sued defendants, a Canadian hockey league (league), member clubs, and a commissioner, alleging claims under the Sherman Antitrust Act, 15 U.S.C.S. § 1. The United States District Court for the Eastern District of Michigan at Detroit granted defendants' motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6). Plaintiffs appealed.

The league permitted each team to carry only three overaged players, which were players who were 20 years of age. The league's "Van Ryn Rule", named after a player who attained free agency in the National Hockey League (NHL) by playing for the league out of college and thus circumvented the NHL draft, restricted a player's access to the league. A collective bargaining agreement (CBA) between the association and the NHL stated that players had to be at least 19 years old to be selected in the NHL draft. Plaintiffs asserted that the Van Ryn Rule prevented players from achieving unrestricted free agency.

  • The court found that plaintiffs failed to sufficiently identify anti-competitive effects of the Van Ryn Rule. 
  • Harm to athletic competition was not a cognizable anti-competitive effect under the Sherman Act. 
  • Furthermore, any harm caused by some players' inability to achieve free agency in the NHL was cased by the CBA and not the Van Ryn Rule. 
  • The Van Ryn Rule, whether adopted by conspiracy between the member clubs of the league or by conspiracy between the league and the NHL, did not cause the anti-competitive effects alleged by plaintiffs.


The judgment was affirmed.

Suggested Study Aid For Sports Law

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