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Keywords

plaintiffdefendantliabilitymotionsummary judgmenttrustregulationantitrustmotion for summary judgment
contractplaintiffdefendantmotionsummary judgmenttrustantitrust

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Association of Independent Television Stations, Inc. v. College Football Ass’n, 637 F.Supp. 1289, 1986-1 Trade Cases P 67,143

Facts

This case involves an antitrust action brought by the Association of Independent Television Stations, Inc. (INTV) and Sports View Company (SVC) against the College Football Association (CFA), the Big Eight Football Conference, and various television networks. The plaintiffs allege that the defendants engaged in illegal practices by fixing prices, limiting output, dividing markets, and excluding competition through their agreements regarding the televising of college football games. The plaintiffs sought summary judgment to establish the antitrust liability of the defendants and to enjoin their collaborative market activities.

The plaintiffs Association of Independent Television Stations, Inc. (INTV) and Sports View Company (SVC) challenge a series of television plans and television rights agreements among the defendants the College Football Association (CFA), the Big Eight Football Conference (the Big Eight), ABC Sports, Inc. (ABC), and Entertainment and Sports Programming Network, Inc. (ESPN) conferring rights to telecast football games played by CFA's and the Big Eight's member colleges and universities.

Issue

Did the agreements between the television networks and the associations of colleges regarding the televising of college football games violate antitrust laws?

Did the agreements between the television networks and the associations of colleges regarding the televising of college football games violate antitrust laws?

Rule

Antitrust laws prohibit unreasonable restraints on trade. Agreements that are so plainly anticompetitive that no elaborate study of the industry is needed to establish their illegality are illegal per se. However, agreements whose competitive effects can only be evaluated by analyzing the facts peculiar to the business must be tested by the rule of reason. The determination of whether a restraint is unreasonable requires consideration of the nature and effect of the restraint as well as the context in which it operates.

Not all combinations that restrain interstate trade or commerce violate antitrust laws; only unreasonable restraints are forbidden and to determine whether restraint is unreasonable, nature and effect of restraint must be considered as well as setting in which its force is felt.

Analysis

In this case, the court found that genuine issues of material fact existed regarding the nature of the agreements and their effects on competition. The plaintiffs did not establish beyond factual dispute that the agreements constituted per se illegal price fixing or market division. The court emphasized that not all agreements among competitors are illegal per se; some may enhance competition. The need for cooperation in the marketing of college football games was recognized, and the court could not determine whether the agreements were permissible intrabrand regulations or illegal interbrand restraints without further factual analysis.

Genuine issues of material fact existed as to whether contracts between television networks and associations of colleges for televising of football games resulted in illegal price fixing.

Conclusion

The court denied the plaintiffs' motion for summary judgment, concluding that genuine issues of material fact precluded a determination of antitrust liability as a matter of law.

Accordingly, INTV's and SVC's motions for summary judgment must be denied.

Who won?

The defendants prevailed in this case as the court denied the plaintiffs' motion for summary judgment. The court found that there were genuine issues of material fact that prevented a determination of antitrust liability. The plaintiffs failed to demonstrate that the agreements in question were illegal per se or that they unreasonably restrained trade. The court recognized the complexities involved in evaluating the competitive effects of the agreements and the necessity of further factual inquiry.

The court determines that these cases present genuine issues of material fact and that INTV and SVC therefore are not entitled to judgment as a matter of law.

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