## Facts

- The United States Football League (USFL) and member teams sued the National Football League (NFL), its clubs, and the Commissioner, alleging Sherman Act §§ 1 and 2 violations aimed at excluding a competing professional football league.
- The USFL alleged an integrated scheme to monopolize major-league professional football, including exclusionary stadium practices, interference with leases, disparagement, control of game officials, and restriction of network television access.
- After a ten-week jury trial in the Southern District of New York, the jury found the NFL liable for willfully acquiring or maintaining monopoly power in a market defined as “major league professional football in the United States.”
- The jury found the monopolization caused injury to the USFL’s business or property but awarded only $1 in damages, which the court trebled to $3 under the Clayton Act.
- The jury rejected the USFL’s other antitrust theories, including § 1 unreasonable restraint of trade and § 2 attempt and conspiracy to monopolize, and rejected key theories tied to a network television submarket.
- Post-trial, the NFL sought judgment notwithstanding the verdict on liability; the USFL sought a new trial or increased damages and broad injunctive relief altering NFL television and league practices.
- The district court denied both sides’ post-trial efforts to overturn the verdict and denied sweeping injunctive relief.
- The USFL appealed seeking broader liability and greater damages; the NFL cross-appealed challenging the § 2 liability finding and trial rulings.

## Issues

1. Whether sufficient evidence supported the jury’s finding that the NFL willfully acquired or maintained monopoly power in the relevant market in violation of Sherman Act § 2.
2. Whether the jury’s award of nominal damages was inconsistent with findings of liability and injury, requiring a new trial or judgment for greater damages.
3. Whether the district court erred in denying broad injunctive relief restructuring the NFL’s television and related practices.
4. Whether the jury’s rejection of the USFL’s remaining § 1 and additional § 2 theories was supported by the record.

## Decision

- The Second Circuit affirmed the judgment in all material respects.
- It upheld the § 2 monopolization verdict based on evidence supporting the relevant market and the NFL’s monopoly power.
- It held the nominal damages award was not internally inconsistent with liability and injury findings and was supported by evidence on causation.
- It affirmed rejection of the USFL’s other antitrust theories, including claims centered on alleged denial of network television access.
- It affirmed the denial of broad injunctive relief, finding no abuse of discretion.

## Legal Principles

- A § 2 monopolization verdict requires proof of monopoly power in a properly defined relevant market and willful acquisition or maintenance of that power, as opposed to growth from superior product or business skill.
- Antitrust liability and antitrust damages are distinct; even with liability and some injury, a jury may award only nominal damages if it finds the defendant’s conduct caused only minimal incremental harm.
- Appellate review respects the jury’s fact findings where supported by sufficient evidence, including market definition, monopoly power, and causation.
- Injunctive relief in antitrust cases is discretionary and may be denied where the proven violation does not justify structural remedies, particularly when the plaintiff fails to prove that specific practices targeted for restructuring were unlawful or causally tied to substantial harm.

## Conclusion

The Second Circuit sustained a finding that the NFL unlawfully maintained monopoly power in the major-league professional football market, but affirmed that the USFL proved only minimal damages and was not entitled to sweeping injunctions altering NFL broadcasting or league operations.


United States Football League v. National Football League, 842 F.2d 1335 (2d Cir. 1988)