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Keywords

contractplaintiffjurisdictiondamagesappealtrialtrustantitrusttreble damagespiracy

damagestrustantitrusttreble damagespiracy

Related Cases

Radovich v. National Football League, 352 U.S. 445, 77 S.Ct. 390, 1 L.Ed.2d 456

Facts

The case involves a professional football player, Radovich, who sued the National Football League (NFL) for treble damages and injunctive relief under antitrust laws. He alleged that the NFL conspired to monopolize professional football and destroy a competing league, the All-America Conference, which he had played in. The lower courts dismissed his complaint for lack of jurisdiction and failure to state a claim. Radovich appealed, leading to a Supreme Court review of whether the business of professional football falls under antitrust laws.

Complaint by professional football player against professional football league for treble damages and injunctive relief because of alleged conspiracy by league to monopolize and control organized professional football and destroy competitive league with the result that player was prevented from becoming a player-coach to his damage, stated a cause of action under the antitrust laws.

Issue

Does the business of organized professional football fall within the scope of federal antitrust laws?

Rule

The Sherman Anti-Trust Act prohibits contracts, combinations, or conspiracies in restraint of trade or commerce among the several States. The Clayton Act allows individuals injured by violations of antitrust laws to sue for treble damages. The sufficiency of a complaint under these laws is determined by whether it states a claim that is not wholly frivolous and whether the plaintiff has suffered injury.

Analysis

The Supreme Court analyzed the allegations made by Radovich, determining that the volume of interstate business involved in professional football is significant enough to fall under the provisions of the antitrust laws. The Court distinguished the business of football from that of baseball, which had previously been exempted from antitrust scrutiny. The Court concluded that the allegations of conspiracy to monopolize and the resulting injury to Radovich were sufficient to state a cause of action under the antitrust laws.

The volume of interstate business involved in organized professional football places it within the provisions of the antitrust laws.

Conclusion

The Supreme Court reversed the lower court's dismissal, holding that the business of organized professional football is subject to federal antitrust laws.

Reversed.

Who won?

The Supreme Court ruled in favor of Radovich, the professional football player, reversing the lower court's decision. The Court found that the allegations of conspiracy to monopolize professional football and the resulting harm to Radovich were sufficient to warrant a trial. This ruling emphasized that the business of professional football, unlike baseball, is subject to antitrust laws due to its significant interstate commerce involvement.

We now turn to the sufficiency of the complaint. At the outset the allegations of the nature and extent of interstate commerce seem to be sufficient.

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