Brown v. Pro Football, Inc.
United States Supreme Court
518 U.S. 231 (1996)
After the NFL and the players' union (NFLPA) failed to reach agreement over pay for a new developmental player squad, the NFL teams collectively implemented their last good-faith offer of a $1,000 weekly salary once negotiations reached impasse. A player, Brown (plaintiff), sued the NFL and the Washington Redskins' operator (defendants) for antitrust violations, and a jury found for the players; the court of appeals reversed, and the Supreme Court granted certiorari.
Whether an employer's conduct occurring during or immediately after collective bargaining, involving a matter the parties were required to negotiate collectively, is shielded from antitrust liability under an implicit, non-statutory labor exemption.