928 F. Supp. 2d 1010
S.D. Ind.2013Background
- Plaintiffs Rock, Steward, and Collins filed July 2012 antitrust suit against NCAA challenging three bylaws: one-year scholarship limit, cap on total athletics-based scholarships, and Division III prohibition on athletics-based scholarships, tied to Agnew.
- Court applies Agnew framework to determine whether plaintiffs state a cognizable Sherman Act claim and have standing.
- Named plaintiffs allege injury from NCAA bylaws as labor-market restraints in college sports; court notes standing varies by plaintiff.
- Collins, a Canadian, is found to lack antitrust standing to challenge the Division III prohibition.
- Rock is found to have standing because he alleges four-year renewal would have occurred without the bylaws; he incurred costs.
- Steward is found to have standing due to injury after giving up a scholarship and incurring private loans when Division III rule prevented continued aid.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Antitrust standing of the named plaintiffs | Rock and Steward have direct injury from bylaws | Collins lacks standing; injuries too indirect | Rock and Steward have standing; Collins lacks standing |
| Cognizable market for Sherman Act claim | Nationwide labor market for student-athletes defined | Market improperly defined; too broad/narrow | Market not cognizable; complaint dismissed on this basis |
| Division III bylaw on athletics-based aid | Division III rule restricts competition; anti-competitive | Rule procompetitive; preserves amateurism | Division III prohibition pro-competitive as matter of law; claim dismissed with prejudice |
Key Cases Cited
- Agnew v. National Collegiate Athletic Association, 683 F.3d 328 (7th Cir. 2012) (labor market for student-athletes must be cognizable; some bylaws procompetitive or not depending on context)
- Board of Regents of the Univ. of Okla. v. NCAA, 468 U.S. 85 (U.S. 1984) (procompetitive justification for NCAA regulations in preserving product quality)
- Marshfield Clinic v. Blue Cross & Blue Shield United of Wisconsin, 65 F.3d 1406 (7th Cir. 1995) (market definition requires consideration of substitution by buyers and sellers)
- Car Carriers, Inc. v. Ford Motor Co., 745 F.2d 1101 (7th Cir. 1984) (market definition and antitrust pleading requirements apply even in motion to dismiss)
- Todd v. Exxon Corp., 275 F.3d 191 (2d Cir. 2001) (substitutability and market plausibility in market definition)