June 21, 2021
Decided June 21, 2021
Nat’l Collegiate Athletic Ass’n v. Alston, No. 20-512; and Am. Athletic Conf. v. Alston, No. 20-520
Today, the Supreme Court unanimously held that the NCAA’s current limits on education-related benefits for student-athletes violate the Sherman Act.
The NCAA imposes eligibility rules fixing the compensation and benefits that member schools can offer student-athletes. The NCAA maintains that its rules, including its restrictions on certain education-related benefits, are necessary to preserve amateurism in college athletics, which is what distinguishes its product from professional sports.
Several student-athletes brought class-action suits against the NCAA and its member conferences, arguing that the restrictions on compensation and benefits run afoul of the Sherman Act. After a bench trial, the district court enjoined the NCAA’s restrictions on education-related benefits after ruling that they violated the Sherman Act. The court ordered the NCAA to allow its member schools to offer athletes education-related benefits such as academic incentive awards and paid, post-eligibility internships. The court did not, however, enjoin NCAA rules that restrict benefits unrelated to education.
The Ninth Circuit affirmed, holding that the NCAA’s limits on education-related benefits violate the Sherman Act, and that allowing student-athletes to receive certain education-related benefits beyond the cost of college attendance, such as paid post-eligibility internships, would not eliminate the distinction between college athletics and professional sports.
Whether the NCAA’s restrictions on education-related benefits for student-athletes violate the Sherman Act.
Yes. The NCAA’s restrictions on education-related benefits violate Section 1 of the Sherman Act. Substantially less restrictive rules that permit student-athletes to receive certain limited education-related benefits would adequately preserve the distinction between college athletics and professional sports.
The district court’s injunction “does not float on a sea of doubt but stands on firm ground—an exhaustive factual record, a thoughtful legal analysis consistent with established antitrust principles, and a healthy dose of judicial humility.”
Justice Gorsuch, writing for the Court
Gibson Dunn submitted an amicus brief on behalf of the Players Associations of the NFL, NBA, WNBA, and National Women’s Soccer League, and the National Collegiate Players Association, in support of respondents: Shawne Alston, et al.
What It Means:
The Court’s opinion is available here.
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