Los Angeles Memorial Coliseum Commission v. National Football League

INTRODUCTION:

I respectfully dissent from the majority’s opinion, insofar as it affirms the district judge’s directed verdict that the N.F.L. was not a single entity as a matter of law.

The dispositive issue before this Court is whether the N.F.L.’s invocation of Rule 4.3 to block the Raiders’ move to Los Angeles violates the letter and spirit of § 1 of the Sherman Act, 15 U.S.C. § 1. I conclude that the N.F.L. is, as a matter of law, a single entity insofar as this aspect of its operations is concerned, and not subject to the strictures of Sherman Act § 1.

These appeals arise from the…