National Hockey League Players Association v. Plymouth Whalers Hockey Club

The National Hockey League Players Association (NHLPA) (plaintiff) and two players, Anthony Aquino and Edward Caron, filed suit against the Ontario Hockey League (OHL) (defendant), which consisted of 20 teams, including teams in Michigan and Pennsylvania, with players aged 16-20. The suit challenged the legality of the “Van Ryn Rule” which banned 20-year-old players who had not previously played professional “major junior” hockey. The OHL, along with the Western Hockey League and the Quebec Major Junior Hockey League, formed the “Major Junior Leagues” of the Canadian Hockey League (CHL), one of three major sources of players in the National Hockey League’s (NHL) draft. One of the OHL’s rules provided that each team could only carry three 20-year-old, or “overage,” players. Additionally, a rule held that no overage player could be signed by an OHL team unless he was previously on a Canadian Hockey Association (CHA) or USA Hockey Player’s Registration the previous season. The National College Athletic Association (NCAA) did not allow players holding either type of registration to play at an NCAA school. When combined, both OHL rules prevented OHL teams from signing any 20-year-old NCAA player because such player would not have been permitted by the NCAA to have obtained the registration required by the OHL. In a prior proceeding (NHLPA I) the district court granted the NHLPA’s request for an injunction preventing enforcement of the Van Ryn Rule. The court of appeals reversed and held that the NHLPA had failed to identify in its complaint the relevant market required under the Sherman Act. After the NHLPA amended its complaint in an attempt to cure the defect, the district court denied injunctive relief. NHLPA and the players appealed.