Brady v. National Football League
640 F.3d 785
8th Cir.2011Background
- NFL and 32 teams appeal district court’s injunction prohibiting an NFL lockout.
- Players filed antitrust and state-law claims on behalf of themselves and similarly situated players.
- District court enjoined the lockout and denied a stay pending appeal.
- NFLPA disclaimed representation of players effective March 11, 2011; union-disclaimer context relevant to labor-law analysis.
- Lockout began March 12, 2011; district court concluded Norris-LaGuardia Act did not bar relief.
- This court granted a stay pending appeal; majority decision grants stay while dissent questions the analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Norris-LaGuardia Act bars injunctions against lockouts post-disclaimer | Players contend NLGA may not bar relief after disclaimer | NFL contends NLGA bars injunctions in lockout cases | Yes, likely to prevail; stay granted on merits |
| Whether district court had jurisdiction under NLGA to enjoin the lockout | District court should enforce antitrust relief despite NLGA | NLGA deprives courts of such jurisdiction | Court likely to prevail on jurisdictional question; stay upheld |
| Whether to grant stay pending expedited appeal (four-factor test) | Stay necessary to preserve players’ interests | Stay necessary to preserve NFL’s negotiating leverage | Stay warranted; balance of harms and public interest favor stay |
Key Cases Cited
- New Negro Alliance v. Sanitary Grocery Co., 303 U.S. 552 (1938) (NLGA applies to labor-dispute related controversies even without union)
- Jacksonville Bulk Terminals, Inc. v. Int'l Longshoremen's Ass'n., 457 U.S. 702 (1982) (NLGA broadly defines labor disputes and involvement)
- Brown v. Pro Football, Inc., 518 U.S. 231 (1996) (nonstatutory labor exemption contexts; union collapse affects labor vs. antitrust balance)
- Brown v. Pro Football, Inc., 50 F.3d 1041 (D.C. Cir. 1995) (discussion of labor exemptions and union status impact)