## Facts

- The United States brought a civil antitrust action under §§ 1 and 2 of the Sherman Act against corporate and individual defendants who controlled a dominant share of professional championship boxing promotion in major venues.
- The complaint alleged defendants promoted professional championship boxing contests on a multistate basis and sold rights to televise, broadcast, and film those contests for interstate transmission.
- The complaint alleged revenue from television, radio, and motion picture rights exceeded 25% of total receipts and sometimes exceeded gate receipts.
- The government alleged defendants conspired to restrain and monopolize the business of promoting championship boxing contests and the associated interstate media rights.
- Defendants argued their conduct was outside the Sherman Act based on professional baseball precedents.
- The district court dismissed the complaint for failure to state a Sherman Act claim, relying on the baseball cases; the United States appealed directly to the Supreme Court under the Expediting Act.

## Issues

1. Whether a complaint alleging multistate promotion of championship boxing contests and sale of interstate media rights sufficiently pleads “trade or commerce among the several States” under the Sherman Act.
2. Whether the professional baseball antitrust decisions create a general exemption for professional sports that would bar Sherman Act claims against boxing promoters at the pleading stage.

## Decision

- The Supreme Court reversed the dismissal and remanded.
- The Court held the complaint stated a cause of action under the Sherman Act.
- The Court held that the alleged business—multistate promotion plus sale of broadcasting, telecasting, and filming rights for interstate transmission—constituted interstate commerce.
- The Court rejected the argument that the baseball cases immunized all professional sports from the Sherman Act.
- The Court emphasized the procedural posture: accepting the allegations as true, the government was entitled to prove them.

## Legal Principles

- A business centered on local events may still be subject to the Sherman Act when it operates on a multistate basis and derives substantial revenue from interstate transactions such as national media rights.
- The relevant commerce inquiry may focus on the defendants’ overall business operations and revenue-generating structure, not solely the local situs of individual events.
- The antitrust treatment of professional baseball is limited to baseball and does not create a general sports exemption; any broader exemption is a matter for Congress.
- On a motion to dismiss, a Sherman Act complaint should proceed if the alleged conduct plausibly involves interstate commerce and unlawful restraint or monopolization.

## Conclusion

The Court held that the government’s allegations about multistate championship boxing promotion and interstate sale of media rights were sufficient to invoke Sherman Act coverage, and it declined to extend baseball’s limited antitrust anomaly to boxing, allowing the case to proceed for proof of the alleged restraints and monopolization.


United States v. Int'l Boxing Club of N.Y., Inc., 348 U.S. 236 (1955)