American Football League vs. National Football League
Case Background
The American Football League (AFL) filed a lawsuit against the National Football League, claiming that the American Football League had breached the Anti-Trust Act. The AFL’s interest in the case was to recover the damages caused by the attempted or existing monopolization of the football league. The AFL informed the court that the NFL monopolized, conspired to monopolize, or tried to monopolize the areas where the AFL could establish franchises, thus making it hard to obtain television contracts (Justia Law, 2024). The NFL, on the other hand, argued that they had no intention of monopolizing and that their actions were only aimed at expanding the NFL League. The NFL also stated that its dominance was because of its contract with CBS, which is one of the organizations with broadcast entitlements on various television networks.
The Law That the Court Based Its Analysis and Why It Is Important
The court based its analysis on the Sherman Antitrust Act. The Sherman Act is important because it prevents unfair competition by categorizing monopoly as a felony. The Act was the appropriate law in the case because, according to Li (2014), the Act prohibits monopolizing trade and conspiring to or attempting to monopolize trade. Therefore, the court relied on the provisions of the Sherman Act on monopolizing to determine whether the NFL was monopolizing or attempted to monopolize and the appropriate course of action against the defendant if they were found guilty of the felony. For example, the court reviewed the Sherman Antitrust Act to determine whether the NFL was willingly controlling the marketplace in response to competition posed by other entities in the market, such as the AFL.
Case Outcome
The case favored the NFL because the jury argued that the NFL had not monopolized and had not attempted to monopolize and did not engage in a conspiracy to monopolize to put limitations on trade. The jury also argued that the NFL’s contracts with television networks did not unreasonably restrain trade, and the NFL did not control their access to the three major television networks. The jury added that the NFL was not involved in hindering the AFL’s ability to acquire television contracts (Justia Law, 2024). However, the AFL did not find the ruling satisfactory, which led to an appeal.
My Position on the Case Outcome
I agree with the case outcome because the NFL did not have control over the broadcasts on the television networks, and their contract with the television networks did not limit the AFL from approaching the networks for a contract. Therefore, the NFL was not monopolizing and did not attempt to monopolize. Besides, a monopoly only exists when willingly taking advantage of a situation that allows an entity or business to benefit over competitors (Skoruks & Šenfelde, 2014). Based on this definition, it can be argued that the NFL had limited control over its dominance in television networks because the television networks controlled the broadcasts.
Appeal
The AFL appealed in the Unit States of Appeal to get an alternative opinion on the legal issue. The Court of Appeal argued that the decision made by the jury in the District Court was valid because the contracts between the NFL and the television networks were not a competitive barrier for other leagues interested in entering a contractual agreement with the networks. The Court of Appeal also stated that the plaintiffs lacked adequate proof to justify their claim that the NFL was monopolizing or was involved in a conspiracy to monopolize. The AFL accepted the Court of Appeal’s ruling, leading to the end of the case.
References
Justia Law. (2024). American Football League v. National Football League, 205 F. Supp. 60 (d. md. 1962). https://law.justia.com/cases/federal/district-courts/FSupp/205/60/2181427/#:~:text=In%20this%20action%20for%20treble,conspiracy%20to%20monopolize%20major%20league
Li, Z. (2014, June 14). The Sherman Antitrust Act (1890) Section 3. Trusts in territories or districts of Columbia are illegal; a combination a felony. Academia.edu. https://www.academia.edu/6737299/The_Sherman_Antitrust_Act_1890_Section_3._Trusts_in_Territories_or_District_of_Columbia_illegal_combination_a_felony
Skoruks, D., & Šenfelde, M. (2014). Econometric methodology of monopolization process evaluation. Business, Management and Education, 12(1), 47–59. https://doi.org/10.3846/bme.2014.04
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Question
This week you will research and read American Football League v. National Football League, 205 F. Supp. 60 (D. Md. 1962). You will need to find the case using Nexis Uni in our Library. You may also need to do additional research. Then, answer the following questions:
1. What was the case about? Summarize the background of the case. (20pts)
2. What law did the Court base their analysis on and why was it important? (20pts)
3. What was the outcome of the case? (10pts)
4. Did you agree or disagree with the outcome and why? (10pts)
5. Shepardize the case in Nexis Uni. Was there a later appeal, and if so what happened? (10pts)