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Clarett v. NFL

Clarett v. NFL

United States Court of Appeals for the Second Circuit

April 19, 2004, Argued ; May 24, 2004, Decided

Docket No. 04-0943

Opinion

 [*125]  SOTOMAYOR, Circuit Judge:

Defendant-appellant National Football League ("NFL" or "the League") appeals from a judgment of the United States District Court for the Southern District of New York (Scheindlin, J.) ordering plaintiff-appellee Maurice Clarett ("Clarett") eligible to enter this year's NFL draft on the ground that the NFL's eligibility rules requiring Clarett to wait at least three full football seasons after his high school graduation before entering the draft violate antitrust laws. In reaching its conclusion, the district court held, inter alia, that the eligibility rules are not immune from [**4]  antitrust scrutiny under the non-statutory labor exemption. 2 We disagree and reverse.

BACKGROUND 

Clarett, former running back for Ohio State University ("OSU") and Big Ten  [*126]  Freshman of the Year, is an accomplished and talented amateur football player. 3 After gaining national attention as a high school player, Clarett became the first college freshman since 1943 to open as a starter at the position of running back for OSU. He led that team through an undefeated season, even scoring the winning touchdown in a double-overtime victory in the 2003 Fiesta Bowl to claim the national championship. 4 Prior to the start of his second college [**5]  season, however, Clarett was suspended from college play by OSU for reasons widely reported but not relevant here. 5 Forced to sit out his entire sophomore season, Clarett is now interested in turning professional by entering the NFL draft. Clarett is precluded from so doing, however, under the NFL's current rules governing draft eligibility.

Founded in 1920, the NFL today is comprised of 32 member clubs and is by far the most successful professional football league in North America. 6 Because of the League's fiscal success and tremendous public following, a career as an NFL player "represents an unparalleled [**6]  opportunity for an aspiring football player in terms of salary, publicity, endorsement opportunities, and level of competition." Clarett, 306 F. Supp. 2d at 384. But since 1925, when Harold "Red" Grange provoked controversy by leaving college to join the Chicago Bears, 7 the NFL has required aspiring professional football players to wait a sufficient period of time after graduating high school to accommodate and encourage college attendance before entering the NFL draft. For much of the League's history, therefore, a player, irrespective of whether he actually attended college or not, was barred from entering the draft until he was at least four football seasons removed from high school. The eligibility rules were relaxed in 1990, however, to permit a player to enter the draft three full seasons after that player's high school graduation.

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369 F.3d 124 *; 2004 U.S. App. LEXIS 10171 **; 174 L.R.R.M. 3185; 149 Lab. Cas. (CCH) P10,345; 2004-1 Trade Cas. (CCH) P74,422

MAURICE CLARETT, Plaintiff-Appellee, v. NATIONAL FOOTBALL LEAGUE, Defendant-Appellant.

Subsequent History: US Supreme Court certiorari denied by Clarett v. NFL, 544 U.S. 961, 125 S. Ct. 1728, 161 L. Ed. 2d 602, 2005 U.S. LEXIS 2979 (2005)

Related proceeding at National Football League v. Vigilant Ins. Co., 2006 N.Y. App. Div. LEXIS 13446 (N.Y. App. Div. 1st Dep't, Nov. 14, 2006)

Prior History:  [**1]  Defendant-appellant National Football League ("NFL") appeals from a judgment of the United States District Court of the Southern District of New York (Scheindlin, J.) granting summary judgment in favor of plaintiff-appellee Maurice Clarett on his claim that the NFL's eligibility rules, which prevent him from entering the NFL draft because he is not more than three football seasons removed from high school, violate the antitrust laws. We hold that the challenged rules are shielded from the antitrust laws by the non-statutory labor exemption and on that basis REVERSE and REMAND for the district court to enter judgment in favor of defendant. As the NFL is entitled to summary judgment, we further VACATE the district court's order declaring Clarett eligible to participate in the 2004 NFL draft that was stayed pending appeal.

Clarett v. NFL, 306 F. Supp. 2d 379, 2004 U.S. Dist. LEXIS 1396 (S.D.N.Y., 2004)

Disposition: Reversed in part, vacated in part and remanded.

CORE TERMS

players, exemption, eligibility rules, bargaining, non-statutory, collective bargaining agreement, collective bargaining, anti trust law, antitrust, negotiations, league, mandatory, district court, bargaining unit, eligibility, teams, multi-employer, federal labor, labor law, terms and conditions, employees, season, policies, salary, professional sports, high school, hired, antitrust liability, collective bargaining process, football season

Civil Procedure, Appeals, Standards of Review, De Novo Review, Summary Judgment Review, Standards of Review, Antitrust & Trade Law, Exemptions & Immunities, Collectives & Cooperatives, Clayton Act, General Overview, Labor, Nonstatutory Exemptions, Statutory Exemptions, Energy & Utilities Law, Antitrust Issues, Mining Industry, Coal Mining, Labor & Employment Law, Collective Bargaining & Labor Relations, Federal Preemption, Primacy of Labor Policy, Regulated Industries, Sports, Sherman Act, Scope, Exemptions, Business & Corporate Compliance, Labor & Employment Law, Bargaining Subjects, Unfair Labor Practices, Duty of Fair Representation, Governments, Courts, Judicial Precedent, Legislation, Effect & Operation, Bargaining Units, Regulated Practices, Monopolies & Monopolization