Fraser v. Major League Soccer
United States Court of Appeals for the First Circuit
284 F.3d 47 (2002)
MLS (defendant) centrally controlled player recruitment, salaries, and team assignments — including spreading marquee players across teams — as a deliberate structural response to the earlier collapse of a rival league attributed to disparate team finances and lack of centralized control. Fraser and other MLS players (plaintiffs) sued alleging Sherman Act Sections 1 and 2 and Clayton Act Section 7 violations; a jury found for MLS, and Fraser appealed.
Whether MLS's centralized control over player recruitment and compensation violated Sherman Act Section 1 (unreasonable restraint of trade), Section 2 (monopolization), or Clayton Act Section 7 (substantially lessening competition through combination) where the plaintiffs failed to establish a properly defined, adversely affected relevant market.