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Brown v. Pro Football, Inc.

United States Supreme Court
518 U.S. 231 (1996)


The National Football League (NFL) (defendant), including member team Washington Redskins (defendant), operated by Pro Football, Inc., implemented six-player development squads with capped salaries. The squads had not previously been part of the collective bargaining process between the teams, the players, and the National Football League Players Association (NFLPA) (plaintiff), which represented players’ interests. Although the NFLPA was not directly opposed to the squads of development players, it requested that the salaries for each of the squad players be individually negotiated, like had been done with other NFL players. The NFL and the NFLPA could not reach an agreement and subsequently implemented its last good-faith wage offer of $1,000 per week salary for the development players. Washington Redskins player, Brown (plaintiff) brought suit alleging violations of federal antitrust laws. The district court jury found for the plaintiffs and defendants appealed. The court of appeals reversed and the U.S. Supreme Court granted certiorari to review.

Rule of Law


Holding and Reasoning (Breyer, J.)

Dissent (Stevens, J.)

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