Smith v. Pro Football, Inc.
United States Court of Appeals for the District of Columbia
593 F.2d 1173 (1978)
Drafted exclusively by the Washington Redskins under the NFL's (defendant) 1968 no-tampering draft rules, which barred any other team from negotiating with him, Smith (plaintiff) accepted a modest $50,000 contract before a career-ending injury, and sued arguing the draft's suppression of competitive bidding cost him a more lucrative, better-protected contract; the district court held for Smith.
Whether a player draft will not violate the Sherman Act under the rule of reason if it is demonstrated to have positive, economically procompetitive benefits that offset its anticompetitive effects, or if it is demonstrated to accomplish legitimate business purposes and have a net anticompetitive effect that is insubstantial.