Maurice Clarett v.

National Football League
2nd Circuit Court of Appeals 369 F.3d 124 (2nd Cir. 2004) Key Search Terms: antitrust, labor law, eligibility, collective bargaining agreements, player’s rights, amateur athlete Facts Maurice Clarett, a collegiate football player, completed his first year at Ohio State University. Clarett was suspended for his entire second year, then sought entry into the professional National Football League. NFL eligibility rules stated that amateur athletes could only apply for the draft after three full collegiate seasons passed or three NFL seasons passed post high school graduation. Clarett did not meet either of these requirements. Clarett filed suit against the NFL claiming the NFL eligibility rules violate antitrust laws. Issue The issue is whether the NFL’s eligibility rule is exempt from antitrust law. Holding The 2nd Circuit reasoned that the primary objective of anti-trust legislation is to preserve business competition. The court of appeals held the eligibility rules are immune from antitrust scrutiny under non-statutory labor exceptions and can only be scrutinized under labor law. The NFL began limiting amateur entrance into the draft in 1925 to prevent injury to young and immature athletes. The issue arises in this case because the NFL players union and the NFL Players Association (NFLPA) collective bargaining agreement at the time did not include the eligibility rules. The eligibility rules were located in the NFL Constitution and Bylaws. The court of appeals reasoned that if the NFLPA wanted to change the eligibility rules they could have brought the issue to the table during bargaining, but did not. The relationship between the NFLPA and the NFL created by the collective bargaining agreement prohibits teams from negotiating directly with players. Clarett claimed this reduced the competitive market of professional football and therefore violated antitrust law. The court held that Clarett’s disagreement with the criteria to enter the draft established by the employer and labor union could only be remedied through labor law, not antitrust. The Court held no antitrust exemption would be made. The 2nd Circuit reversed and remanded the case with instruction to enter judgment in favor of the NFL. Summarized By: Vanessa Sheehan

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