Mid-South Grizzlies v. NFL
United States Court of Appeals for the Third Circuit
720 F.2d 772 (1983)
The Mid-South Grizzlies (plaintiff), a professional football team formed from players of a defunct rival league, applied to the NFL (defendant) for a franchise, which the NFL rejected citing recent expansions elsewhere, scheduling needs for an even number of teams, and labor-relations uncertainty. The Grizzlies sued alleging antitrust violations and violation of a statute granting sports leagues limited antitrust immunity for merging only if the merger increased the number of professional football clubs; the closest existing NFL team to the Grizzlies' Memphis location was over 280 miles away. The district court granted the NFL summary judgment, and the Grizzlies appealed.
Whether a football team seeking admission to the NFL as a franchise will prevail under section 1 of the Sherman Act if it shows no actual or potential injury to competition resulting from the rejection of its application.