Jason White et al. v. National Collegiate Athletic Association

Jason White et al. v. National Collegiate Athletic Association

Case Summary

The Jason White et al. v. National Collegiate Athletic Association case involved a former Stanford football player and the National Collegiate Athletic Association. Jason White filed a class-action lawsuit challenging the restrictions set by the NCAA on athletic scholarships’ monetary value (White v. NCAA, 2006). The Plaintiffs argued that the grant-in-aid used by the NCAA was a strategy aimed at saving costs rather than a way of promoting competition among student-athletes. The Plaintiffs also added that the NCAA agreement harms competition because if there was no agreement, major university and college men’s football and basketball teams would hold competitions with one another to ensure that the financial aid package was equal to their entire attendance cost.

Basis of the Court Analysis

The Court considered the Sherman Antitrust Act to analyze the case. The Act prohibits activities that restrict interstate competition and commerce (Hovenkamp,2021). The Sherman Antitrust Act was important in the case because the Court had to determine whether the NCAA’s grant-in-aid unreasonably restricted trade by limiting interstate competitions.

The Outcome of the Case

The NCAA acknowledged that the grant-aid policy required some changes. Each plaintiff got $5000 from the settlement. The NCAA also paid a $10 million concession to each student-athlete represented in the lawsuit and $8.6 million for attorney fees. The NCAA also created a new $218 million fund and a rule that included providing scholarships to student-athletes for five years.

The Court’s Decision

The Court upheld the lower Court’s ruling, stating that the NCAA’s move to dismiss the case was adequately supported by the Second Amended Complaint’s allegations that the NCAA and its member establishments had an agreement to uphold the grant-in-aid cap when awarding student-athletes financial aid.

Reason for the Court’s Decision

The Court made its decision the way it did because the defendants did not sufficiently plead a relevant market. The defendants also failed to sufficiently claim that NCAA’s actions damaged competition.

The Legal Standard Employed

The Court used the rule of reason to rule the case. According to Baker et al. (2011), the rule of reason includes three steps. In the first step, the plaintiffs were required to provide evidence of their allegations of anticompetitive impact within a legitimately cognizable appropriate market. The second step required the defendant to demonstrate that the pro-competitive qualities of behavior were more than the anticompetitive qualities. The third step required the Court to establish if the impact could be reached through a different action that puts fewer limitations on competition.

The Prior Cases that the Court Relied Upon

The Court based its decision on the O’Bannon V. NCAA case that involved challenging the use of student-athletes for commercial purposes. In the case, the district court ruled that the amateurism rules used by the NCAA were an unlawful trade restriction.

Agreement with the Outcome

I agree with the case’s outcome because the NCAA was using the grant-aid cap to increase its profits by saving costs, thus placing the student-athletes who dictated third time and energy to win games at a disadvantage. Therefore, there was a need to hold the NCAA accountable for its actions to prevent the development of a culture that allowed football clubs to use student-athletes to increase their revenue and profits.

What to Mention About the Case

The Jason White et al. v. National Collegiate Athletic Association case was unique because it focused on pushing the Court to decide whether the grant-in-aid cap and its financial limits were reasonable by arguing that schools should match the financial aid with the cost of attendance. The case is also a landmark because it led to the changes in NCAA’s grant-in-aid policy. The Court was also not “divided” because the defendants presented strong arguments to support their claim. Therefore, my thought on the case is that it was resolved successfully because the NCAA had been accused of using student-athletes to increase profits in the O’Bannon V. NCAA case.

References

Baker, T. A., Maxcy, J. G., & Thomas, C. (2011). White v. NCAA: A Chink in the Antitrust Armor The plain. Journal of Legal Aspects of Sport, 21(1), 75–99. https://doi.org/10.1123/jlas.21.1.75

Hovenkamp, H. (2021). Monopolizing and the Sherman Act. SSRN Electronic Journal. https://doi.org/10.2139/ssrn.3963245

White v. NCAA, 2006 U.S. Dist. LEXIS 101374, 2006 WL 8066803 (United States District Court for the Central District of California October 19, 2006, Filed). https://advance-lexis-com.ezproxy1.apus.edu/api/document? collection=cases&id=urn:contentItem:59W4-1G91-F04C-T566-00000-00& context=1516831.

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This week you will research and read Jason White, et al. v. National Collegiate Athletic Association. You will need to find the case using Nexis Uni in our Library. You may also need to do additional research. Then, please answer the following questions:

Jason White et al. v. National Collegiate Athletic Association

What was the case about? Who did what to whom? Please include all facts the court considered significant. Summarize in your own words. DO NOT cut and paste from the opinion.
What law did the Court base its analysis on and why was it important?
What was the outcome of the case?
Did the court affirm the lower court’s decision, reverse it, and/or remand it for additional proceedings?
Why did the court decide the case the way it did?
What legal standard did they use or establish?
What prior cases did the Court rely upon and why?
Did you agree or disagree with the outcome and why?
Is there anything else that should be mentioned about this case? Is it a “landmark” case? Was the court “divided”? What were your personal thoughts on the case?