Maurice Clarett v. National Football League
2004 U.S. App. LEXIS 10171, 174 L.R.R.M. (BNA) 3185, 369 F.3d 124 (2004)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The non-statutory labor exemption immunizes a professional sports league's player eligibility rules from antitrust scrutiny when those rules are mandatory subjects of bargaining within an established collective bargaining relationship.
Facts:
- Maurice Clarett was a star running back for Ohio State University during his freshman year, leading the team to a national championship.
- Prior to his sophomore season, Ohio State University suspended Clarett from college play.
- Forced to sit out the season and wanting to turn professional, Clarett sought to enter the upcoming National Football League (NFL) draft.
- Since 1990, the NFL has maintained a rule making players ineligible for the draft until three full football seasons have passed since their high school graduation.
- Clarett had graduated high school in December 2001, making him one season short of the eligibility requirement for the 2004 NFL draft.
- The eligibility rule is not explicitly written in the collective bargaining agreement (CBA) between the NFL and the NFL Players Association (NFLPA).
- The rule is contained within the NFL Constitution and Bylaws, which are referenced multiple times in the CBA.
- The CBA includes a provision in which the NFLPA waives its right to bargain over the contents of the NFL Constitution and Bylaws for the duration of the agreement, unless a proposed change could significantly affect player employment conditions.
Procedural Posture:
- Maurice Clarett filed suit against the National Football League in the United States District Court for the Southern District of New York.
- Clarett alleged that the NFL's draft eligibility rules were an unreasonable restraint of trade in violation of the Sherman Act and Clayton Act.
- Both parties moved for summary judgment.
- The district court granted summary judgment for Clarett, holding the eligibility rules were not immune from antitrust scrutiny under the non-statutory labor exemption and were an illegal restraint of trade.
- The district court ordered Clarett eligible to enter the 2004 NFL draft.
- The National Football League (appellant) appealed the judgment to the United States Court of Appeals for the Second Circuit, with Maurice Clarett as the appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the non-statutory labor exemption to antitrust laws shield the National Football League's rule, which requires a player to be three seasons out of high school to be draft-eligible, from an antitrust challenge?
Opinions:
Majority - Sotomayor, Circuit Judge.
Yes. The non-statutory labor exemption shields the NFL's eligibility rule from antitrust attack. The court reasoned that the inception of a collective bargaining relationship irrevocably alters the governing legal regime, shifting disputes over terms and conditions of employment from the realm of antitrust law to that of labor law. The court found that the eligibility rules are a mandatory subject of collective bargaining because they represent a literal condition for initial employment and have tangible effects on the wages and working conditions of current players, such as job security for veterans. The fact that the rules affect prospective employees like Clarett, rather than current union members, does not remove them from the protection of the exemption, as this is analogous to permissible union hiring hall arrangements. Because the NFL teams act as a multi-employer bargaining unit, they are permitted under labor policy to act jointly in setting such employment criteria. The court concluded that even though the rules were not explicitly included in the CBA, the union had acquiesced to their continuing operation by agreeing to a waiver clause in the CBA, making the rules part of the 'unique bundle of compromises' protected from antitrust scrutiny.
Analysis:
This decision significantly reinforces the power of the non-statutory labor exemption in professional sports, effectively insulating league rules on player eligibility, drafts, and salary caps from antitrust challenges as long as a collective bargaining relationship is in place. It prioritizes the stability of the collective bargaining process and federal labor policy over the individual competitive interests of prospective employees. The ruling establishes a strong precedent that makes it exceedingly difficult for aspiring athletes to challenge league entry rules on antitrust grounds, forcing them instead to seek remedies through the players' union and the mechanisms of labor law.
