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In re National Collegiate Athletic Association Athletic Grant-In-Aid Cap Antitrust Litigation
United States District Court for the Northern District of California
375 F. Supp. 3d 1058, 2019 U.S. Dist. LEXIS 44512 (2019)
The National Collegiate Athletic Association (NCAA) and 11 NCAA conferences (defendants) organized intercollegiate football and basketball competitions for elite college athletes (Division I). The NCAA and its conferences were an effective monopsony for Division I athletes, who had no viable alternative but to comply with the arrangement. The NCAA regulated or limited how much student athletes could receive in compensation as follows: (1) there was a limit on “grant-in-aid” comprising tuition and fees, room and board, and books and other expenses related to attendance, calculated based on the cost of attendance at each school; (2) there were specified regulations on how much student athletes could receive in compensation and benefits, both related and unrelated to education, from various assistance funds, government sources, and outside entities; and (3) all other compensation was generally prohibited. Current and former student athletes who played Division I football and basketball (the players) (plaintiffs) sued the NCAA alleging violations of the Sherman Antitrust Act (Sherman Act). On summary judgment, the court found that the existence of an agreement restraining trade and affecting interstate commerce was undisputed. The court further found that the NCAA’s rules restrained trade because they limited the compensation that student athletes would otherwise receive. The court held a nonjury trial during which evidence was presented regarding the market effects of the NCAA’s rules.
Rule of Law
Holding and Reasoning (Wilken, J.)
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