## Facts

- Barbara Jane Blalock was a professional golfer and LPGA member who competed for profit in LPGA-sponsored tournaments.
- The LPGA, an Ohio corporation, operated professional women’s golf tournaments and wholly owned the LPGA Tournament Players Corporation, which handled business matters.
- LPGA policies and affairs were directed by an Executive Board composed of active player-officers who regularly competed against Blalock.
- At an LPGA tournament in Louisville, Kentucky (May 1972), the tournament director appointed observers to watch Blalock’s play; the observers accused her of rules violations involving moving her ball.
- The Executive Board decided to disqualify Blalock from the Louisville tournament, fine her $500, and place her on probation for the remainder of the season.
- The Board later extended the discipline to a one-year suspension without providing Blalock another hearing.
- LPGA rules substantially restricted members from playing in non-LPGA events without authorization, so suspension from LPGA tournaments effectively excluded a player from the principal market for professional women’s golf services.

## Issues

1. Whether the LPGA and its player-competitor Executive Board engaged in a per se unlawful group boycott (concerted refusal to deal) under § 1 of the Sherman Act by imposing a one-year suspension that effectively excluded Blalock from the relevant market.
2. Whether LPGA’s asserted self-regulatory character justified avoiding per se treatment for the suspension.

## Decision

- The court granted Blalock’s motion for partial summary judgment on liability under Sherman Act § 1.
- The court denied the defendants’ motions for summary judgment.
- The court held that the one-year suspension constituted a per se unlawful group boycott (concerted refusal to deal).

## Legal Principles

- A competitor-controlled agreement that excludes a rival from access to the primary venue for offering services can constitute a group boycott and be condemned as a per se violation of Sherman Act § 1.
- Concerted action exists when economically interested competitors jointly apply membership/eligibility rules to exclude another competitor from competition.
- Exclusionary discipline by a private association is not insulated from antitrust scrutiny absent statutory authorization and regulatory oversight comparable to recognized, government-supervised self-regulatory regimes.
- When the challenged restraint effectively forecloses participation in the relevant market, per se analysis may apply without a full rule-of-reason inquiry.
- Summary judgment is appropriate on a § 1 claim when the material facts establishing concerted exclusion and market foreclosure are undisputed and the restraint fits within a per se category.

## Conclusion

The court held that the LPGA Executive Board’s one-year suspension of Blalock—imposed by active player-competitors and functioning as effective market exclusion—was a per se illegal group boycott under Sherman Act § 1, warranting partial summary judgment for Blalock on antitrust liability.


Blalock v. Ladies Pro. Golf Ass’n, 359 F. Supp. 1260 (N.D. Ga. 1973)