Sullivan v. NFL - 34 F.3d 1091 (1st Cir. 1994)

Rule:

As long as a judge's instruction properly apprises the jury of the applicable law, failure to give the exact instruction requested does not prejudice the objecting party. A party, however, is entitled to have its legal theories on controlling issues, which are supported by the law and by the evidence, presented to the jury. An error in the jury instructions will warrant the reversal of the judgment and a new trial only if, upon review of the record as a whole, the error is determined to be prejudicial.

Facts:

The National Football League and twenty-one organizations owning NFL franchises (referred to collectively as the "NFL") appeal the judgment entered against them after a jury found that the NFL violated the antitrust laws by restricting owners of member football clubs from selling shares in their teams to the public. Plaintiff-appellee, William H. Sullivan, former owner of the New England Patriots football team (the "Patriots"), was awarded a total of $51 million in damages for the losses Sullivan incurred when he had to sell the Patriots to a private buyer after the NFL prevented him from offering 49% of the team to the public in the form of publicly traded stock. 

Issue:

Was the failure to give certain jury instructions a prejudicial error?

Answer:

Yes.

Conclusion:

The court reversed and remanded the decision, holding that a new trial was required because the district court improperly allowed evidence concerning the fairness of the NFL’s policy, instead of manners concerning trade restraints.