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Brady v. National Football League

United States Court of Appeals for the Eighth Circuit
644 F.3d 661 (2011)


Facts

The National Football League (NFL) (defendant) held a non-statutory labor exemption from the Sherman Antitrust Act on account of the NFL Players Association’s (NFLPA) status as the collective bargaining representative union for NFL players. The NFL and NFLPA engaged in more than two years of negotiations on the parties’ next collective bargaining agreement (CBA). The NFL planned to lockout the players if the parties did not reach a new CBA. Before the CBA expired, the NFL players voted to disclaim the NFLPA as their collective bargaining representative. On the same day, Brady and other NFL players (players) (plaintiffs) brought an antitrust suit against the NFL, seeking a preliminary injunction enjoining the NFL from instituting the planned lockout. The players asserted that because they disclaimed the union, the NFL’s antitrust exemption no longer applied. The district court granted the players’ motion for a preliminary injunction. The NFL appealed, claiming the Norris-LaGuardia Act, 29 U.S.C. § 101 (NLGA), prohibited the injunction, restricting the ability of courts to grant injunctions in labor disputes.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

Dissent (Bye, J.)

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