National Collegiate Athletic Association v. Alston

The National Collegiate Athletic Association (NCAA) (defendant) was an organization that regulated college sports, including football and basketball. The NCAA had a monopoly over college athletics and was very profitable, receiving over a billion dollars each year from television contracts alone. At the same time, the NCAA restricted the compensation that colleges and universities could offer their student athletes, implementing rules limiting education- and performance-related payments. A group of student athletes (the plaintiff athletes) (plaintiffs) filed a lawsuit in federal district court against the NCAA, alleging that the NCAA’s rules limiting student-athlete compensation involved anticompetitive price-fixing in violation § 1 of the Sherman Act. The NCAA defended its compensation-limiting rules, arguing that its compensation limits promoted amateurism and distinguished college athletics from professional athletics. At trial, the district court conducted a fact-intensive rule-of-reason analysis and determined that the NCAA’s limits on education-related compensation violated § 1 by unreasonably restraining competition among schools for college athletes. In making its determination, the district the court found that the NCAA could adopt less restrictive rules while still promoting college athletics. The court of appeals affirmed the district court. The NCAA appealed, arguing that the district court erred by conducting a full rule-of-reason analysis instead of a quick-look analysis. In its argument, the NCAA highlighted the fact that the United States Supreme Court had previously applied a quick-look analysis in a case involving the NCAA’s rules, NCAA v. Board of Regents of the University of Oklahoma. The Supreme Court granted certiorari.