Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

defendantappealtrialverdicttrustantitrustdue processjury trial
contracttortplaintiffdefendantdamagesverdicttrustwillantitrustdue processtreble damages

Related Cases

Kentucky Speedway, LLC v. National Ass’n of Stock Car Auto Racing, Inc., 588 F.3d 908, 2010-1 Trade Cases P 76,875
View Case »
Feight v. Hansen, 81 S.D. 84, 131 N.W.2d 64
View Case »
Mayes v. La Sierra University, 73 Cal.App.5th 686, 288 Cal.Rptr.3d 693, 398 Ed. Law Rep. 1046, 22 Cal. Daily Op. Serv. 463, 2022 Daily Journal D.A.R. 340
View Case »
New York Times Co. v. Sullivan, 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686, 95 A.L.R.2d 1412, 1 Media L. Rep. 1527
View Case »
Karr v. Schmidt, 460 F.2d 609
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Behagen v. Amateur Basketball Ass’n of U.S., 884 F.2d 524, 1989-2 Trade Cases P 68,727

Facts

Ronald Behagen, a former professional basketball player, sued the Amateur Basketball Association of the United States (ABA/USA) and its executive director after being denied reinstatement to amateur status. Behagen had played professionally and sought to regain his amateur status to participate in international competitions. The ABA/USA informed him that he was ineligible due to a no-second-reinstatement rule. After a jury trial, the jury found in favor of Behagen on his antitrust and due process claims, leading to an appeal by the defendants.

Behagen brought suit against FIBA, the ABA/USA, and William Wall, seeking the following relief: 1) treble damages for violations of the federal antitrust laws; 2) damages for tortious interference with contract; and 3) damages for the deprivation of liberty or property interests without due process of law.

Issue

Whether the actions of the ABA/USA in refusing to reinstate Behagen's amateur status were exempt from federal antitrust laws and whether the ABA/USA was a governmental actor subject to due process requirements.

Whether the actions of the ABA/USA in refusing to reinstate Behagen's amateur status were exempt from federal antitrust laws and whether the ABA/USA was a governmental actor subject to due process requirements.

Rule

The actions of the ABA/USA in denying reinstatement to amateur status are exempt from federal antitrust laws due to the congressional intent expressed in the Amateur Sports Act, which mandates monolithic control over amateur sports. Additionally, the ABA/USA is considered a private entity and not a governmental actor, thus not subject to due process protections.

Actions of the amateur basketball association in refusing to reinstate former professional basketball player's amateur status were exempt from the federal antitrust laws where monolithic control exerted by the association over its amateur sport was a direct result of congressional intent expressed in the Amateur Sports Act and the association could not be authorized under the Act unless it maintained exactly that degree of control over its sport that was alleged as an antitrust violation.

Analysis

The court analyzed the Amateur Sports Act and determined that the ABA/USA's control over amateur basketball was necessary to implement congressional intent, thereby exempting its actions from antitrust laws. Furthermore, the court concluded that the ABA/USA's role as a national governing body did not equate to governmental action, as it did not perform a traditional governmental function and was not subject to constitutional constraints.

We hold that the antitrust claim is barred by the express intent of Congress and that the due process claim is barred by a lack of governmental action. We reverse.

Conclusion

The court reversed the lower court's judgment, holding that the ABA/USA's actions were exempt from federal antitrust laws and that the due process claim was invalid due to the lack of governmental action.

We reverse the judgment of the district court on the antitrust issue because of the clear intent of Congress to exempt the defendants' actions here from the federal antitrust laws. We reverse the district court's judgment on the due process issue, for want of the requisite governmental action.

Who won?

Ronald Behagen prevailed in the jury trial, successfully arguing that the ABA/USA's refusal to reinstate him was a violation of his rights under federal antitrust laws and due process. The jury's verdict in his favor indicated that they found merit in his claims regarding the unfairness of the ABA/USA's actions and the impact on his ability to participate in amateur basketball.

The jury rendered its verdict in favor of the defendants on the tortious interference with contract count, but in favor of the plaintiff on the antitrust and due process counts.

You must be