## Facts

- A newly formed professional football league (AFL) and its member clubs competed with an established league (NFL) and its member clubs in markets for players, coaches, stadium access, and television rights.
- The AFL sued the NFL and affiliated defendants under Sherman Act §§ 1 and 2, alleging coordinated conduct intended to exclude the AFL from key cities and media markets and to preserve NFL dominance.
- The challenged conduct included alleged interference with stadium leasing decisions (including exclusive arrangements) and the NFL’s television contracting practices.
- The case was tried to the court, which heard extensive evidence concerning league structure, competitive conditions, and alleged exclusionary acts.
- The district court entered judgment for the defendants, finding the AFL failed to prove an unlawful restraint of trade, monopolization/attempted monopolization, or that defendants’ conduct proximately caused the AFL’s claimed injuries.
- The Fourth Circuit affirmed, and certiorari was denied.

## Issues

1. Whether the NFL and its member clubs entered into an agreement that unreasonably restrained trade in violation of Sherman Act § 1 by coordinating to deny the AFL access to stadiums and television opportunities.
2. Whether the NFL monopolized or attempted to monopolize the business of professional football in violation of Sherman Act § 2 through exclusionary or predatory conduct aimed at suppressing the AFL.
3. Whether the AFL proved that any unlawful conduct proximately caused antitrust injury, as distinct from harms attributable to the ordinary risks of launching a rival sports league.

## Decision

- The Fourth Circuit affirmed the judgment for the NFL and its member clubs.
- The court accepted the district court’s findings of fact as not clearly erroneous.
- The evidence did not establish an unlawful conspiracy or unreasonable restraint of trade under § 1.
- The evidence did not establish monopolization or attempted monopolization under § 2, including a coordinated plan to destroy the AFL.
- The AFL failed to prove proximate causation and antitrust injury tied to unlawful conduct.

## Legal Principles

- In evaluating claimed restraints within a professional sports league, courts may distinguish cooperation necessary to produce league competition from unlawful concerted action restraining trade.
- A plaintiff asserting a Sherman Act § 1 claim must prove an agreement and that the restraint is unreasonable under applicable antitrust standards.
- A Sherman Act § 2 claim requires proof of monopoly power (or dangerous probability for attempt) and willful maintenance or acquisition of that power through exclusionary conduct rather than legitimate competitive success.
- Exclusive or favorable stadium leasing arrangements, without proof of coercion or coordinated exclusionary action, may be treated as independent decisions by local facility owners rather than league-wide unlawful conduct.
- Competition for television rights and revenue is not itself unlawful absent proof that contracting practices constitute an unreasonable restraint or exclusionary scheme.
- Antitrust plaintiffs must prove antitrust injury and proximate causation; business difficulties inherent in market entry do not substitute for proof that unlawful conduct caused the harm.

## Conclusion

The Fourth Circuit upheld judgment for the NFL because the AFL did not prove that the NFL’s league-level coordination and competitive responses amounted to an unreasonable restraint of trade or monopolization, and it did not show that any unlawful conduct proximately caused the AFL’s alleged injuries.


American Football League v. National Football League, 323 F.2d 124 (4th Cir. 1963)