Hecht v. Pro-Football, Inc. (Washington Redskins)
United States Court of Appeals for the District of Columbia
570 F.2d 982 (1977)
In 1965, American Football League (AFL) owners wanted to expand into Washington, D.C., which already had an NFL team, the Washington Redskins, owned by Pro-Football, Inc. (defendant). Hecht and his partners (plaintiff) sought to secure a stadium lease for an AFL franchise, but the only viable venue, RFK Stadium, was under a 30-year lease held by the Redskins from the federal government. Although the Interior Department was willing to lease space to an AFL team, the Redskins refused to share the stadium. Hecht sued the Redskins and the NFL for violating §2 of the Sherman Act. A jury found for the Redskins and NFL, and Hecht appealed several aspects of the trial court's jury instructions.
Whether a football stadium can be treated as a scarce "essential facility" under antitrust law that its owner must share with a would-be competitor when sharing is practical, and whether the trial court properly instructed the jury on the relevant geographic market, the burden of proving monopolistic intent, and the essential-facilities doctrine.