## Facts

- Division I football and basketball student-athletes filed a class action challenging NCAA limits on student-athlete compensation as unlawful restraints of trade under Sherman Act § 1.
- The NCAA and its member schools agreed on and enforced compensation restrictions that affected interstate commerce.
- The district court, after a bench trial, found significant anticompetitive effects in the labor market for student-athletes’ services from rules restricting education-related benefits.
- The district court accepted that preserving demand for a distinct college-sports product could be a procompetitive justification, but found less restrictive alternatives available for education-related benefits.
- The district court enjoined NCAA rules capping education-related benefits and certain academic/graduation awards (up to set amounts), while allowing the NCAA to impose reasonable definitional limits and anti-evasion measures.
- The Ninth Circuit affirmed, emphasizing the injunction’s narrow scope and its consistency with rule-of-reason analysis.
- The Supreme Court granted certiorari and reviewed whether the injunction and underlying rule-of-reason analysis complied with antitrust principles.

## Issues

1. Whether NCAA rules limiting education-related benefits available to student-athletes constitute unreasonable restraints of trade under Sherman Act § 1 when evaluated under the rule of reason.
2. Whether the district court’s tailored injunction enjoining certain caps on education-related benefits is consistent with established antitrust remedial principles.

## Decision

- The Supreme Court unanimously affirmed.
- The Court held that the district court’s injunction regarding limits on education-related benefits was consistent with established antitrust principles.
- The Court declined to adopt the NCAA’s requested highly deferential standard that would effectively insulate compensation restraints based on “amateurism.”
- The Court treated the case as fact-bound and upheld the district court’s rule-of-reason findings and its narrow remedy.
- The decision did not require schools to pay salaries or permit unlimited cash compensation unrelated to education; it addressed only education-related benefits.

## Legal Principles

- Agreements among competitors restraining compensation in a labor market are subject to Sherman Act § 1 scrutiny and ordinarily assessed under the rule of reason.
- Joint ventures (including sports leagues) may require coordination, but that need does not create blanket antitrust immunity; restraints must still be justified under rule-of-reason analysis.
- Prior references to “amateurism” do not establish a categorical antitrust exemption for NCAA compensation restraints.
- Under the rule of reason, courts may credit procompetitive justifications yet require that restraints be no more restrictive than reasonably necessary; less restrictive alternatives can support liability.
- Antitrust injunctions may be narrowly tailored to enjoin unlawful restraints while permitting reasonable, non-pretextual limits and enforcement rules to prevent evasion.

## Conclusion

The Court upheld a limited injunction barring NCAA caps on education-related benefits because, under the rule of reason, those restraints unreasonably restricted competition in the market for student-athletes’ services, while leaving the NCAA room to police reasonable definitions and prevent circumvention without mandating pay-for-play.


NCAA v. Alston, 594 U.S. 69 (2021)