Brown V. Pro Football

Brown v. Pro Football, Inc. United States Supreme Court 518 U.S. 231 (1996) Key Search Terms: antitrust, collective-bargaining, union, “nonstatutory” labor exemption, immunity Facts Following the conclusion of a collective-bargaining agreement between the NFL, a group of football clubs, and the NFL Players Association, the Players Association and the NFL began to negotiate a new contract. The NFL adopted Resolution G-2 which generally involved allowing each club a developmental squad comprised of players who did not make the rosters of any team. The negotiations reached an impasse after the NFL presented a provision requiring clubs to pay each developmental squad member the same weekly salary of $1,000 and uniform benefits. After two months of the stalemate, the NFL unilaterally imposed the provision and sent each team a uniform contract to be used for each squad member of their developmental team. Issue The issue is whether the league’s decision to require standardized contracts for the developmental squads violated the Sherman Antitrust Act. Holding The Supreme Court held that the implicit “nonstatutory” exemption applied to the owners conduct when they implemented the contracts, thus the NFL did not violate any antitrust rules. The Court reasoned that the agreement was lawful because it was made following the last best good-faith wage offer. The Court determined this based on the following factors: the contract took place during and immediately following the collective bargaining negotiation, it evolved from a lawful bargaining process, it involved a matter which parties are required to negotiate collectively, and it only concerned parties to the collectivebargaining relationship. Summarized By: Erika Nelson