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Keywords

contractdamagesinjunctiontrustclass actionantitrust

jurisdictioninjunctiontrustantitrust

Related Cases

Robertson v. National Basketball Ass’n, 389 F.Supp. 867, 88 L.R.R.M. (BNA) 2787, 19 Fed.R.Serv.2d 982, 76 Lab.Cas. P 10,729, 1975-1 Trade Cases P 60,168

Facts

This case involves a group of present and former basketball players who filed an antitrust action against the National Basketball Association (NBA) and the American Basketball Association (ABA). The players alleged that the NBA's reserve clause, uniform player contract, and college draft violated antitrust laws by restraining competition for their services. They sought to prevent a proposed merger between the two leagues and claimed that these practices were not mandatory subjects of collective bargaining. The court found that the players had standing to sue on behalf of themselves and future players.

Issue

Did the NBA and ABA violate antitrust laws through the use of the reserve clause, uniform player contract, and college draft, and could the players' claims proceed as a class action?

Whether a claimed violation of the Sherman Antitrust Act which falls within the regulatory scope of the National Labor Relations Act is within the exclusive primary jurisdiction of the National Labor Relations Board.

Rule

The court applied the Sherman Act and Clayton Act to determine whether the practices in question constituted illegal restraints of trade. It held that the reserve clause, college draft, and uniform player contract were per se violations of antitrust laws. The court also ruled that the players had standing to bring the action and that the claims could proceed as a class action.

The College Draft is allegedly designed to prevent competition among member NBA clubs for what it virtually the exclusive source of basketball talent in the country.

Analysis

The court analyzed the practices of the NBA and ABA, concluding that the reserve clause and college draft effectively eliminated competition for players' services. It found that these practices were not subject to the labor exemption from antitrust laws, as they did not arise from collective bargaining. The court also determined that the proposed merger between the leagues would further restrain competition, justifying the players' claims.

The court analyzed the practices of the NBA and ABA, concluding that the reserve clause and college draft effectively eliminated competition for players' services.

Conclusion

The court ruled in favor of the players, allowing their antitrust claims to proceed and maintaining the injunction against the merger of the NBA and ABA.

Who won?

The players prevailed in their antitrust action against the NBA and ABA. The court recognized their standing to sue and ruled that the practices employed by the leagues constituted illegal restraints of trade under antitrust laws. The court's decision emphasized the importance of competition in professional sports and rejected the leagues' claims of labor exemption, thereby allowing the players to seek damages and injunctive relief.

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Smith v. Pro Football, Inc., 593 F.2d 1173, 193 U.S.App.D.C. 19, 1978-2 Trade Cases P 62,338, 1978-2 Trade Cases P 62,375

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Eriksson v. Nunnink, 191 Cal.App.4th 826, 120 Cal.Rptr.3d 90, 11 Cal. Daily Op. Serv. 380, 2011 Daily Journal D.A.R. 468

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