National Hockey League Players Association v. Plymouth Whalers Hockey Club
United States Court of Appeals for the Sixth Circuit
419 F.3d 462 (2005)
The NHL Players Association and two affected players (plaintiffs) challenged the Ontario Hockey League's (OHL) (defendant) "Van Ryn Rule," which barred 20-year-old players who had not previously played major junior hockey, arguing it violated the Sherman Act by, among other effects, foreclosing certain players' path to NHL free agency and diluting talent in the OHL labor pool. After the district court initially granted an injunction, the court of appeals reversed for failure to plead a relevant market; on remand with an amended complaint, the district court again denied injunctive relief, and the plaintiffs appealed again.
Whether a relevant market under a rule-of-reason antitrust analysis includes employment positions or products reasonably interchangeable with, not merely identical to, those affected by the challenged rule.