Bowman v. National Football League
402 F. Supp. 754 (1975)
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Rule of Law:
A concerted agreement by a professional sports league and its member teams to refuse to deal with a specific class of players constitutes a group boycott that is likely to violate federal antitrust laws.
Facts:
- A group of professional football players were under contract with teams in the World Football League (WFL) during the 1975 season.
- The WFL ceased operations mid-season, leaving its players unemployed.
- The National Football League (NFL) and its member teams adopted a resolution specifically for the 1975 season.
- The resolution prohibited any NFL club from signing a player who had been under contract with another major professional football league in 1975.
- While an exception existed for players whose league ceased to operate, it imposed a final signing deadline of October 24, 1975, for the remainder of the season.
- This signing restriction did not apply to other unemployed professional football players who had not been part of the WFL.
Procedural Posture:
- Former World Football League players filed a class-action lawsuit in the U.S. District Court against the National Football League and its member teams.
- The complaint alleged that the defendants' hiring restrictions violated the Sherman and Clayton Antitrust Acts.
- Plaintiffs moved for a preliminary injunction to prevent the NFL from enforcing its resolution that barred them from signing contracts for the remainder of the 1975 season.
- The district court held a hearing on the motion for a preliminary injunction.
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Issue:
Does a professional sports league's resolution that prohibits its member teams from signing players from a recently defunct rival league for the remainder of the current season constitute a group boycott in likely violation of the Sherman and Clayton Acts?
Opinions:
Majority - Devitt, Chief Judge
Yes. A resolution by a professional sports league to prohibit its teams from signing players from a defunct rival league is a concerted boycott that likely violates federal antitrust laws. The court found that the plaintiffs were likely to succeed in proving that the NFL and its teams conspired to restrain competition for the players' services, which constitutes a classic antitrust violation under established precedent. The court reasoned that the plaintiffs would suffer irreparable harm to their careers, finances, and physical conditioning if the injunction were not granted, as this time out of the sport could not be compensated by monetary damages. In contrast, the potential harm to the NFL from granting the injunction was less significant. Finally, the public interest is better served by open and unfettered competition for playing positions.
Analysis:
This case is significant for applying traditional antitrust principles, specifically the prohibition against group boycotts, to the professional sports labor market. It establishes that a dominant sports league cannot use its collective, monopolistic power to foreclose employment opportunities for a class of competitors, in this case, players from a rival league. The court's willingness to grant a preliminary injunction underscores the irreparable harm athletes face when their short careers are interrupted. This decision reinforces that league-wide rules restricting player movement and hiring are subject to antitrust scrutiny and cannot be justified solely by claims of maintaining competitive balance or administrative convenience.
