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defendantappealtrustantitrust
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American Football League v. National Football League, 323 F.2d 124

Facts

The American Football League (AFL) filed a private antitrust action against the National Football League (NFL), claiming that the NFL had monopolized the market for professional football teams. The case was heard in the United States District Court for the District of Maryland, where the court found that the NFL did not possess the power to monopolize the relevant market. The AFL appealed the decision, arguing that the NFL's actions were anti-competitive and violated the Sherman Anti-Trust Act.

The American Football League and owners of its franchises are contending against the National Football League and the owners of its franchises for victory in the courts. The American Football League and the owners of its franchises lost in the Court below, when the District Court held that there had been no violation of Sections 1, 2 or 3 of the Sherman Act by the National Football League and the owners of its franchises.

Issue

Did the National Football League possess monopoly power in the relevant market for professional football teams, and did it engage in anti-competitive practices in violation of the Sherman Anti-Trust Act?

Did the National Football League possess monopoly power in the relevant market for professional football teams, and did it engage in anti-competitive practices in violation of the Sherman Anti-Trust Act?

Rule

To establish a violation of the Sherman Anti-Trust Act, there must be evidence of monopoly power in a relevant market and an attempt to monopolize that market. The relevant market is defined by the geographic area in which the defendant operates and the competitive dynamics within that area. A natural monopoly is not a violation unless it is misused to gain competitive advantage.

Analysis

The court analyzed the evidence presented by both leagues regarding their market positions and competitive practices. It found that the NFL did not have the power to monopolize the market for professional football teams, as there were numerous cities available for franchise locations and the AFL was able to successfully establish itself in direct competition with the NFL. The court also noted that the NFL's expansion plans were based on legitimate business considerations rather than an intent to suppress competition.

Conclusion

The court affirmed the lower court's ruling that the NFL did not violate the Sherman Anti-Trust Act, concluding that there was substantial evidence supporting the finding that the NFL lacked monopoly power in the relevant market.

We affirm.

Who won?

The National Football League prevailed in this case, as the court found that it did not possess monopoly power over the market for professional football teams. The court's decision was based on substantial evidence that indicated the NFL's actions were not anti-competitive and that the AFL was able to compete effectively in the market. The court emphasized that the existence of multiple potential franchise locations and the successful operation of the AFL demonstrated that the NFL's market position was not monopolistic.

The National Football League was first upon the scene. In 1959, it had franchises in eleven cities, the two Chicago teams being in direct competition with each other. It now has franchises in fourteen cities, some of which the District Court found capable of supporting more than one professional football team.

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