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American Football League v. National Football League

American Football League v. National Football League, 205 F. Supp. 60 (D. Md. 1962)
PARTIES: The American Football league (AFL) and the owners of its franchises were the plaintiffs whereas the National Football League (NFL) and the owners of its franchises were the defendants.
FACTS: The AFL and its owners filed suit against NFL and its owners under the Sherman Act. The plaintiffs accused the defendants of monopolizing, trying to monopolize, and scheming to monopolize the professional football market. For this reason, the District Court was required to make a decision as to whether the NFL had monopolized the metropolitan regions in which franchises could successfully locate, if NFL had monopolized the recruitment of players, and if NFL had monopolized television rights sales (Quinn, 2011). In this regard, the court ruled in favour of NFL and stated that there were no violations of Sections 1, 2 or 3 of the Sherman Act by the defendants. The AFL and the owners of its franchises appealed the decision of the District Court.
PROCEDURAL HISTORY: The AFL and the owners of its franchises wanted the court to find NFL and the owners of its franchises culpable of violating the Sherman Act by monopolizing the football league. The AFL decided to take NFL to court after NFL provided franchises to be located in various states around the country for the single purpose of averting the organization of the American league (Quirk, 2014).
ISSUE(S): In making its decision, the District Court had raised various questions: did the AFL teams sign 6 of the first 12 choices of NFL teams in the 1959 draft? Did the NFL have power to stop the AFL from signing a sufficient number of qualified players? Did the NFL have power to leave out the AFL from sufficient television outlets, and was there monopoly exercised in this area?

HOLDING: The Court made its conclusion with regard to players, quoting evidence that the AFL teams had signed 6 of the 1st 12 choices of NFL teams in the 1959 draft. The court concluded that the NFL did not have any power to prevent the AFL from signing a sufficient number of players who were qualified (Gruver, 2011). The court also concluded that the NFL had no power to leave out the AFL from sufficient television outlets, and subsequently, there was no monopoly exercised in this area.
REASONING: The court mainly relied on the Sherman Act in making its decision. The Sherman Act widely forbids (i) anticompetitive agreements and (ii) unilateral conduct that takes over or tries to monopolize the pertinent market. As such, based on the evidence presented, the court concluded that the defendant had not violated the Sherman Act. The court relied on several previous cases to make its decision, they included: United States v. Griffith, 334 U.S. 100, 106-109, 68 S. Ct. 941, 92 L. Ed. 1236; and Mandeville Island Farms, Inc. v. American Crystal Sugar Co., 334 U.S. 219. These cases were relied upon because they both addressed the monopoly issue and the Sherman Act.
DECISION: The appellate court affirmed the District Court’s decision. According to the appellate court, the pertinent market was countrywide. This court stated that the AFL had competed successfully for players, and had gotten beneficial contracts for countrywide television coverage (Wong, 2010). This kind of evidence strongly bolstered the finding that the defendants (NFL and owners of its franchises) lacked the power to hinder the formation of AFL’s league. The fact that the accused enjoyed an innate monopoly was not tantamount to a breach of the antitrust laws unless the innate monopoly power of defendants’ teams was abused to obtain a competitive advantage for teams located in other towns, or for defendants’ league in general (Wong, 2010). The appellate court further stated that there was nothing in the nature of a concerted promotion by NFL to frustrate the ambitions of plaintiff owners to devastate the AFL league.
COMMENTS: The court made its decision in unison and no discrepancies were found in the courts opinions. I support the court’s decision since NFL’s actions were not tantamount to monopolizing the football league; it only sought to grow talents across the various states in the country.

Gruver, E. (2011). The American Football League: A Year-by-Year History, 1960–1969.
Quinn, K. G. (2011). The Economics of the National Football League: The State of the Art.
Berlin, Germany: Springer Science & Business Media.
Quirk, C. E. (2014). Sports and the Law: Major Legal Cases. London, England: Routledge.
Wong, G. M. (2010). Essentials of Sports Law. ABC-CLIO.

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