Smith v. Pro Football, Inc. case brief

Smith v. Pro Football, Inc. case brief summary
593 F.2d 1173 (1978)

CASE SYNOPSIS

Defendants appealed the award of treble damages under the Sherman Act, 15 U.S.C.S. §§ 1-3, by the U.S. District Court for the District of Columbia due to the boycott imposed by defendants through their football player draft system, and both defendants and plaintiff appealed the computation of damages.

CASE FACTS
A player's antitrust complaint, under the Sherman Act, 15 U.S.C.S. §§ 1-3, challenged the professional football draft system then in effect. If the player could not agree with the team that drafted him, the player could not play in professional football.

DISCUSSION

• The court held the draft was not an illegal per se classic group boycott because its purpose was not to exclude competition at the same level as the football league. 
• The league operated more as a joint venture than as horizontal competitors with an interest in driving each other out of business. 
• Under the rule of reason, the court held the draft was illegal because its conceded purpose was to restrain teams' competition for graduating college players, it had anticompetitive effect greater than available alternatives, and its pro-competitive virtues were not shown. 
• The court remanded consideration of damages because there was no evidence at the time of multiyear guarantees for rookies regardless of injury.

CONCLUSION
The court affirmed that the football player draft system then in effect was a group boycott that was illegal when measured under the rule of reason but remanded the case for further damage computations.

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