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The US Court of Appeals for the Ninth Circuit affirms a jury’s verdict that an agreement entered by competitive sports teams constitute an unreasonable restraint of trade in the market for professional football teams and their home stadiums (LA Mem’l Coliseum Comm’n / NFL)

The Ninth Circuit Court of Appeals, applying a rule of reason analysis, affirmed a jury verdict that an agreement between NFL teams requiring a 2/3 vote before allowing one team to move within the home territory of another team violated the Sherman Act, Section 1. Rejecting the NFL’s arguments, the Court first reasoned that the NFL constituted an association of independent entities, who were cable of conspiring together and did not count as a “single” entity to escape liability under Section 1. The Court then found that the jury could reasonably have concluded from the evidence that the NFL’s policy effectively divided territories among its members and was an unreasonable restraint of trade. This suit arose from the NFL’s restrictions on allowing teams to move their home stadiums and the

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Katherine Whitehead Miller, The US Court of Appeals for the Ninth Circuit affirms a jury’s verdict that an agreement entered by competitive sports teams constitute an unreasonable restraint of trade in the market for professional football teams and their home stadiums (LA Mem’l Coliseum Comm’n / NFL), 28 February 1984, e-Competitions February 1984, Art. N° 62477

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