## Facts

- After the St. Louis Cardinals relocated in 1988, Missouri and local governments pursued an NFL team and assigned that task to the St. Louis Convention & Visitors Commission (CVC), a public entity that also controlled stadium leasing.
- St. Louis constructed a domed stadium as part of a convention complex, intending to secure either an expansion team or an existing franchise through a stadium lease.
- The NFL Constitution’s Article 4.3 required approval by three-fourths of member clubs for a team relocation and listed factors clubs should consider in relocation votes.
- After expansion efforts failed, CVC pursued the Los Angeles Rams; CVC negotiated exclusively with the Rams and did not seek other lease bids once negotiations began.
- NFL owners initially voted against the Rams’ relocation, partly because the Rams resisted a relocation fee the league considered appropriate.
- CVC and the Rams agreed confidentially that CVC would pay part of any required relocation fee; the Rams ultimately agreed to a relocation fee of about $29 million, with CVC contributing $20 million.
- The NFL approved the Rams’ move, and the Rams began playing in St. Louis in 1995.
- CVC later experienced financial shortfalls under the lease financing structure and sued the NFL and member clubs, alleging the relocation rules and fee practices deterred other teams from bidding for the St. Louis lease and forced CVC into unfavorable lease terms and relocation-fee subsidies.

## Issues

1. Whether the NFL’s relocation approval rules and relocation-fee practices constituted an unreasonable restraint of trade under Sherman Act § 1 under the rule of reason.
2. Whether CVC proved antitrust injury and causation linking the challenged restraints to its claimed damages (unfavorable lease terms and relocation-fee payments).
3. Whether the NFL tortiously interfered with CVC’s contractual or business relationships under Missouri law.
4. Whether the NFL and its member clubs should be treated as a single entity for § 1 purposes (cross-appeal).

## Decision

- The Eighth Circuit affirmed judgment for the NFL on CVC’s Sherman Act § 1 claim.
- The court held CVC’s proof was insufficient for a reasonable jury to find an unreasonable restraint of trade, antitrust injury, or causation under the rule of reason.
- The Eighth Circuit affirmed judgment for the NFL on CVC’s tortious-interference claim for lack of evidence of improper, unjustified interference.
- The court declined to decide the NFL’s single-entity cross-appeal because affirmance on the merits made it unnecessary.

## Legal Principles

- Under the rule of reason, a plaintiff must present evidence of actual anticompetitive effects in a properly defined competitive context and a non-speculative causal link between the challenged conduct and the claimed harm.
- Antitrust injury requires harm of the type the antitrust laws prevent—harm to competition—not merely a plaintiff’s financial loss from an unfavorable deal.
- A theory that the plaintiff would have obtained better contract terms in a hypothetical competitive “but-for” market must be supported by concrete evidence, not conjecture about absent bidders or alternative negotiations.
- In a joint sports league context, collective governance mechanisms related to producing the league product (including coordination on franchise location) are evaluated for competitive effects; their existence alone does not establish § 1 liability.
- Tortious interference requires proof of improper interference without justification; conduct taken to advance the defendant’s legitimate business interests, absent wrongful means or intent to injure, is insufficient.

## Conclusion

The Eighth Circuit held that CVC did not substantiate, with non-speculative evidence, that the NFL’s relocation approval process and relocation-fee practices restrained competition or caused antitrust injury, and it also failed to prove improper interference under Missouri law; accordingly, the court affirmed judgment for the NFL and did not reach the league’s single-entity argument.


St. Louis Convention & Visitors Comm’n v. Nat’l Football League, 154 F.3d 851 (8th Cir. 1998)