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Keywords

contractlawsuitjurisdictiondamagesappealtrialtrustregulationantitrust

contractdamagestrustregulationantitrust

Related Cases

Partee v. San Diego Chargers Football Co., 34 Cal.3d 378, 668 P.2d 674, 194 Cal.Rptr. 367, 1983-2 Trade Cases P 65,588

Facts

Dennis Partee, a professional football player, played for the San Diego Chargers from 1968 to 1976. In 1974, he received a contract offer from the World Football League for $50,000, but he signed a contract with the Chargers for lower salaries. Partee later filed a lawsuit claiming that the Chargers violated the California antitrust law, specifically the Cartwright Act, by adhering to certain NFL operating rules that he argued imposed unreasonable restraints on player transfers. The trial court awarded him damages based on this claim.

From 1968 to 1976, Dennis Partee, a California resident, played professional football as a punter and placekicker for the Chargers, a member of the National Football League (NFL). In 1974, the World Football League came into existence, and one of its teams offered Partee $50,000 to play for it for a season. He subsequently entered into a contract with the Chargers for three years with a salary of $38,500 in 1974, $44,000 in 1975, and $49,500 in 1976.

Issue

Is the application of California's Cartwright Act to professional football precluded by the presence of interstate commerce and concurrent Sherman Act jurisdiction?

Rule

The Cartwright Act, California's antitrust law, is not applicable to the interstate activities of professional football due to the necessity of national uniformity in regulation. The burden on interstate commerce outweighs the state interests in applying state antitrust laws to the player-team-league relationships in professional football, as established in prior cases like Flood v. Kuhn.

The Cartwright Act is not applicable to the interstate activities of professional football. (Flood v. Kuhn (1972) 407 U.S. 258, 92 S.Ct. 2099, 32 L.Ed.2d 728.)

Analysis

The court analyzed the relationship between the NFL's operating rules and the impact of state antitrust laws on interstate commerce. It concluded that applying the Cartwright Act would create an unreasonable burden on interstate commerce, similar to the findings in Flood v. Kuhn regarding baseball. The court emphasized that professional football operates as a nationwide business, and differing state regulations could disrupt the league's structure and competitive balance.

We are satisfied that national uniformity required in regulation of baseball and its reserve system is likewise required in the player-team-league relationships challenged by Partee and that the burden on interstate commerce outweighs the state interests in applying state antitrust laws to those relationships.

Conclusion

The court reversed the trial court's judgment awarding damages under the Cartwright Act, concluding that the Act is not applicable to the interstate activities of professional football.

The judgment is reversed insofar as it awards damages on the basis of violation of the Cartwright Act.

Who won?

The San Diego Chargers Football Company prevailed in the appeal, as the court ruled that the Cartwright Act could not be applied to their interstate activities. The court's reasoning was based on the need for national uniformity in the regulation of professional football, which operates across state lines and is significantly impacted by federal antitrust laws. The court found that the burden on interstate commerce outweighed any state interest in regulating the NFL's practices.

The Chargers contend that professional football is a unique activity of interstate commerce which requires nationally uniform governance, that only federal antitrust laws apply, that interstate commerce would be unreasonably burdened if state antitrust laws were applied to professional football's interstate activities.

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