## Facts

- Emil Weser sought to play in the Western Open, a golf tournament co-sponsored by the Professional Golfers’ Association of America (PGA).
- Entry into the tournament was limited to golfers who satisfied the PGA’s eligibility criteria for PGA events.
- Weser did not qualify under any listed eligibility category and was not allowed to enter the tournament field.
- The primary route to eligibility was successful completion of the PGA’s qualifying school.
- The number of golfers who could qualify through qualifying school each year was tied to the number of available openings on the PGA tour.
- PGA regulations also identified nine additional eligibility categories for PGA tournaments, including (among others) the 25 lowest-scoring golfers at the PGA Championship, winners of specified tournaments, and PGA section champions.
- Weser filed suit alleging the PGA’s eligibility requirements violated federal antitrust law by excluding him from tournament competition.
- The PGA moved to dismiss and explained that its limits were aimed at maintaining a high level of play and were also driven by operational constraints, including golf-course capacity, the time needed for players to complete rounds, and practical limits such as access to private courses and the availability of tournament volunteers.

## Issues

1. Whether the PGA’s eligibility criteria for entry into a co-sponsored PGA tournament could constitute an unlawful restraint of trade under the federal antitrust laws.
2. Whether a complaint alleging a single golfer’s exclusion from a PGA tournament sufficiently alleged anticompetitive harm, as opposed to harm only to the individual plaintiff.

## Decision

- The U.S. District Court for the Northern District of Illinois granted the PGA’s motion to dismiss.
- The court dismissed Weser’s antitrust challenge to the PGA’s eligibility rules governing entry into the Western Open.

## Legal Principles

- Antitrust law does not treat every exclusionary rule by a sports organization as unlawful; the challenged restraint must be plausibly alleged to unreasonably restrict competition.
- A plaintiff challenging league or tour participation rules must allege harm to competition in a relevant market, not merely the plaintiff’s inability to participate in a particular event.
- Eligibility limits connected to the nature of the competition (including the quality of play) and to non-pretextual constraints on staging an event (including finite field size and time limits) can serve as legitimate justifications that weigh against finding an unreasonable restraint at the pleading stage.

## Conclusion

In *Weser v. PGA*, 1979—2 Trade Cases (CCH) 78,180 (N.D. Ill. 1979), the court dismissed an antitrust suit brought by a golfer excluded from the Western Open for failing to meet PGA eligibility criteria, accepting that the rules and field limits were tied to competitive quality and real-world tournament constraints rather than an unlawful restraint of trade.


Weser v. PGA, 1979—2 Trade Cases (CCH) 78,180