Facts of the Case

After their collective-bargaining agreement expired, the National Football League (NFL) -- a group of football clubs -- and the NFL Players Association -- a labor union -- began to negotiate a new contract. The NFL presented a plan that would permit each club to establish a "developmental squad" of substitute players, each of whom would be paid the same $1,000 weekly salary. The union disagreed. When the negotiations reached an impasse, the NFL unilaterally implemented the plan. A number of squad players brought an antitrust suit, claiming that the employers' plan unfairly restrained trade. The District Court awarded damages to the players, but the Court of Appeals reversed that decision.

Question

Are several employers immune from a union anti-trust suit when these employers, bargaining together, unilaterally impose terms on the union if the collective bargaining process reaches an impasse?

Conclusion

Yes. In affirming the Court of Appeals decision, the Supreme Court held that federal labor laws protect professional football franchises from anti-trust actions brought by their players when those franchises unilaterally impose terms after the collective bargaining process breaks down. Labor laws stabilize, encourage, and protect the collective bargaining process. When that process breaks down, labor laws provide adequate remedies. Employee suits under the Sherman Anti-Trust Act, by contrast, might undermine the integrity of collective bargaining and preempt unnecessarily the labor laws.