Banks v. NCAA
United States Court of Appeals for the Seventh Circuit
977 F.2d 1081 (1992)
Braxton Banks (plaintiff), Notre Dame's starting fullback, sat out his senior year with a knee injury, then entered the NFL draft and signed with an agent, forfeiting his remaining college eligibility under NCAA (defendant) rules. No NFL team drafted him because of the injury, and when he returned to Notre Dame, the NCAA refused to waive its no-draft/no-agent rules to let him play again. Banks sued the NCAA for violating § 1 of the Sherman Act. The district court dismissed his complaint under Rule 12(b)(6).
Whether an NCAA rule may be deemed a restraint of trade under § 1 of the Sherman Act where the plaintiff shows it is a term of employment that diminishes competition in the relevant market.