Law School Case Brief
RADOVICH v. NFL - 352 U.S. 445, 77 S. Ct. 390 (1957)
A final judgment against a defendant in proceedings by the government for violation of the antitrust laws may be introduced by a private litigant in a subsequent treble damage action. The judgment establishes prima facie a violation of the antitrust laws. In the face of such a policy the court should not add requirements to burden the private litigant beyond what is specifically set forth by Congress in the law.
Radovich, a professional football player, brought an action against the National Football League (“NFL”) and others for violation of 1 and 2 of the Sherman Anti-trust Act. He alleged in his complaint that the NFL blacklisted him because he broke his contract with a club affiliated with the league by taking employment with another club without consent of the club holding his contract. This blacklisting effectively prevented his employment in organized football and was the result of a conspiracy among the defendants to monopolize interstate commerce in professional football. It was also alleged that radio and television transmission of football exhibitions was an integral part of NFL’s business. The District Court dismissed the cause for lack of jurisdiction and failure to state a claim on which relief could be granted. The United States Court of Appeals for the Ninth Circuit affirmed, holding that the business of professional baseball was not within the scope of the federal anti-trust laws.
Does the business of professional baseball fall within the scope of the federal anti-trust laws.?
The United States Supreme Court reviewed the antitrust laws and concluded that they were applicable to NFL. The Court acknowledged the case law stating that baseball was outside the scope of the antitrust laws, but concluded that such an exception was narrowly construed and was not authority for exempting other businesses. Radovich's complaint did not lack jurisdiction because the allegations of interstate commerce and claim regarding radio and television transmissions were sufficient to establish jurisdiction. Radovich's complaint stated a claim on which relief could be granted because it sufficiently alleged that NFL'S acts violated the Sherman Act and caused petitioner injury.
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