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Maurice Clarett v.

National Football League

2nd Circuit Court of Appeals
369 F.3d 124 (2nd Cir. 2004)

Key Search Terms: antitrust, labor law, eligibility, collective bargaining

agreements, player’s rights, amateur athlete

Maurice Clarett, a collegiate football player, completed his first year at Ohio
State University. Clarett was suspended for his entire second year, then sought
entry into the professional National Football League. NFL eligibility rules stated
that amateur athletes could only apply for the draft after three full collegiate
seasons passed or three NFL seasons passed post high school graduation.
Clarett did not meet either of these requirements. Clarett filed suit against the
NFL claiming the NFL eligibility rules violate antitrust laws.

The issue is whether the NFL’s eligibility rule is exempt from antitrust law.

The 2nd Circuit reasoned that the primary objective of anti-trust legislation is
to preserve business competition. The court of appeals held the eligibility rules
are immune from antitrust scrutiny under non-statutory labor exceptions and
can only be scrutinized under labor law. The NFL began limiting amateur
entrance into the draft in 1925 to prevent injury to young and immature
athletes. The issue arises in this case because the NFL players union and the
NFL Players Association (NFLPA) collective bargaining agreement at the time
did not include the eligibility rules. The eligibility rules were located in the NFL
Constitution and Bylaws. The court of appeals reasoned that if the NFLPA
wanted to change the eligibility rules they could have brought the issue to the
table during bargaining, but did not. The relationship between the NFLPA and
the NFL created by the collective bargaining agreement prohibits teams from
negotiating directly with players. Clarett claimed this reduced the competitive
market of professional football and therefore violated antitrust law. The court
held that Clarett’s disagreement with the criteria to enter the draft established
by the employer and labor union could only be remedied through labor law, not
antitrust. The Court held no antitrust exemption would be made. The 2nd
Circuit reversed and remanded the case with instruction to enter judgment in
favor of the NFL.

Summarized By: Vanessa Sheehan