Sullivan v. National Football League

United States Court of Appeals for the First Circuit

34 F.3d 1091 (1994)

Relevant factsFree

Sullivan (plaintiff), owner of the New England Patriots, wanted to sell a non-controlling public share of the team, but the NFL's (defendant) policy against public ownership forced him to sell the team for far less than its value; he sued under the Sherman Act, and a jury awarded him damages, which the NFL appealed.

IssueFree

Whether, under a Rule of Reason analysis, a restraint of trade violates § 1 of the Sherman Act if the policy's anticompetitive effects outweigh its legitimate business justifications.

Holding & reasoning

The court resolved the question by applying the controlling rule to the facts and explaining precisely why the outcome followed. Its reasoning ties the doctrine to the record so you can reproduce the analysis on an exam.

Procedural history, concurrence & dissent

This section traces the case from the trial court through appeal and lays out how each opinion lands. Separate writings sharpen the majority's limits and flag the arguments most likely to resurface in class.

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