## Facts

- Jack Molinas, a professional basketball player, signed to play for the Fort Wayne Pistons in 1953.
- In January 1954, Molinas admitted in writing that he placed multiple bets on his own team to win and received money from those wagers.
- Molinas’s player contract (Section 15) and the NBA Constitution (Section 79) prohibited gambling.
- NBA Commissioner Maurice Podoloff indefinitely suspended Molinas under the anti-gambling provisions, and the suspension remained in effect at the time of suit.
- Molinas made repeated requests for reinstatement; the NBA refused, and Podoloff stated he would not permit Molinas to return to the league.
- After the suspension, Molinas attended law school, was admitted to the New York bar, and played professional basketball outside the NBA.
- Molinas previously brought unsuccessful New York state-court actions challenging the suspension and seeking reinstatement.
- In this federal action, Molinas alleged the NBA, its commissioner, and member clubs conspired to restrain trade, and that enforcement of the anti-gambling rule and the league’s reserve clause unlawfully restrained the market for his playing services under federal antitrust law.
- Molinas sought treble damages, injunctive relief, and reinstatement.

## Issues

1. Whether the NBA’s anti-gambling rule and Molinas’s indefinite suspension pursuant to that rule constituted an unreasonable restraint of trade in violation of the Sherman Act.
2. Whether the NBA’s reserve clause and related league arrangements unlawfully restrained trade as applied to Molinas.
3. Whether Molinas proved antitrust causation and compensable injury resulting from any alleged antitrust violation.

## Decision

- The court dismissed the complaint on the merits.
- The court held Molinas failed to prove an antitrust violation that caused him compensable harm.
- The court concluded enforcement of the anti-gambling rule and the resulting suspension were reasonable measures to protect the integrity of professional basketball, not an unreasonable restraint of trade.
- The court found Molinas did not establish that the reserve clause or other league arrangements caused his claimed losses.

## Legal Principles

- Under the Sherman Act, liability requires proof of an unreasonable restraint of trade and a causal link between the challenged conduct and the plaintiff’s claimed damages.
- League rules reasonably directed to preserving the honesty and integrity of athletic competition, including discipline for gambling, may be lawful under a rule-of-reason analysis.
- A plaintiff who is excluded due to misconduct must still prove that the exclusion resulted from anticompetitive conduct, rather than justified disciplinary enforcement.
- Allegations of conspiracy and ancillary restraints require evidentiary support; unsupported assertions are insufficient to establish an antitrust violation.

## Conclusion

The court rejected Molinas’s antitrust challenge because the NBA’s gambling prohibition and disciplinary suspension were treated as legitimate integrity-based regulation, and Molinas failed to prove that any unlawful restraint—whether the suspension, the reserve clause, or other alleged practices—caused his asserted economic injury.


Molinas v. Nat'l Basketball Ass'n, 190 F. Supp. 241 (S.D.N.Y. 1961)