Haywood V. National Basketball Association

Haywood v. National Basketball Association United States Supreme Court 401 U.S. 1204 (1971) Key Search Terms: Sherman Act, antitrust, NBA, injunction, player draft Facts Haywood left college early and signed with the NBA’s Seattle Supersonics when he was 21 years of age. This action violated NBA rules at the time because Haywoood was signed less than four years after he had graduated from high school. The NBA threatened to disallow the contract and sanction the Seattle Supersonics. Haywood implemented a cause of action alleging that the NBA’s action was a per se violation of the Sherman Act. The District Court ultimately granted an injunction pendent lite allowing him to play for Seattle and forbidding the NBA from sanctioning the team. The Ninth Circuit stayed the injunction. Issue The issue on appeal was the legality of the NBA’s professional player draft and whether an injunction was the appropriate remedy. Holding The NBA rule at the time prohibited a college player from being drafted until four years after he graduated from high school. The Supreme Court stated that the draft binds the player to the team which selected him but the NBA does not enjoy an exemption from antitrust law. The Supreme Court considered that if Haywood could not play Seattle would probably not make the playoffs. The court stated that if he was allowed to play but Seattle did not make the playoffs, no harm would occur. But if Haywood is allowed to play and the district court decision goes in favor of the NBA, it will be up to the district court to determine whether the NBA could disregard all of Seattle’s victories while he played. On this basis, the Supreme Court reinstated the injunction against the NBA, stating that to dissolve the stay would preserve the interest and integrity of the playoff system.

Summarized By: Brian Raterman