Dist. Ct. did not err in dismissing on pleadings plaintiff-college football player’s class action alleging that defendant-college association’s rule requiring student athletes who transfer to Division 1 college to wait one full academic year before they can play for new school constituted unlawful restraint of trade in violation of section 1 of Sherman Act. Dismissal was appropriate since year-in-residence requirement was eligibility rule clearly meant to preserve amateur character of college athletics, and thus was presumptively pro-competitive under Bd. of Regents, 468 U.S. 85 and Agnew, 683 F.3d 328. As such, rule was not required to be tested for anti-competitive effect under full rule-of-reason analysis. Ct. further noted that uninhibited transfers with immediate eligibility to play would risk severing athletic and academic aspects of college sports and threaten character of intercollegiate athletics. Fact that defendant’s rule had limited exceptions did not require different result.
Federal 7th Circuit Court
Civil Court
Anti-Trust