American Needle, Inc. v. National Football League et al. (560 U.S. 183)

U.S. Supreme Court · decided May 24, 2010 · Supreme Court Database (Spaeth)

Citation
560 U.S. 183 · 130 S. Ct. 2201
Decided
May 24, 2010
Term
October Term 2009
Vote
9–0
Majority author
Justice Stevens
Issue area
Economic Activity
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Liberal

Opinion excerpt

Justice Stevens delivered the opinion of the Court. “Every contract, combination in the form of a trust or otherwise, or conspiracy, in restraint of trade” is made illegal by § 1 of the Sherman Act, ch. 647,26 Stat, 209, as amended, 15 U. S. C. § 1. The question whether an arrangement is a contract, combination, or conspiracy is different from and antecedent to the question whether it unreasonably restrains trade. This case raises that antecedent question about the business of the 32 teams in the National Football League (NFL) and a corporate entity that they formed to manage their intellectual property. We conclude that the NFL's licensing activities constitute concerted action that is not categorically beyond the coverage of § 1. The legality of that concerted action must be judged under the Rule of Reason. I Originally organized in 1920, the NFL is an unincorporated association that now includes 32 separately owned professional football teams. Each team has its own name, colors, and logo, and owns related intellectual property. Like each of the other teams in the league, the New Orleans Saints and the Indianapolis Colts, for example, have their own distinctive names, colors, and marks that are well known to millions of sports fans. Prior to 1963, the teams made their own arrangements for licensing their intellectual property and marketing trademarked items such as caps and…

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