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United States Football League v. National Football League

634 F. Supp. 1155 (1986)

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United States Football League v. National Football League

United States District Court for the Southern District of New York

634 F. Supp. 1155 (1986)

Facts

The United States Football League (USFL) and some of its clubs (collectively, the USFL) (plaintiffs) sued a competing football league, the National Football League (NFL), its commissioner, and some NFL members (collectively, the NFL) (defendants). The USFL’s operative complaint alleged violations of § 1 and § 2 of the Sherman Act based on various anticompetitive acts that assertedly formed part of an integrated plan to monopolize, attempt to monopolize, or conspire to monopolize the market for professional football games. The USFL was allegedly unable to obtain a network-television contract as a result of the NFL’s conduct. The USFL sought to introduce evidence of the NFL’s prior anticompetitive conduct toward a different football league, the World Football League (WFL), as well as numerous prior judgments and antitrust lawsuits involving the NFL. Among various factual allegations in the omnibus complaint, the USFL claimed that the NFL (1) had prevented and interfered with the USFL’s access to stadiums and stadium leases (the stadium-related claims); (2) had convinced state or local government authorities not to grant leases to the USFL on the USFL’s desired terms (government-petition claims); (3) had made nonspecific “disparaging” remarks about the USFL to the press (disparagement claims); and (4) had monopolized, attempted to monopolize, and conspired to monopolize the market for qualified game officials to the USFL’s detriment. The NFL filed a motion for partial summary judgment.

Rule of Law

Issue

Holding and Reasoning (Leisure, J.)

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