National Collegiate Athletic Assn. v. Alston

Summary

**National Collegiate Athletic Assn. v. Alston, 594 U.S. ___ (2021)** **Topics:** Antitrust – Sherman Act §1 – Rule of Reason – Horizontal Price Fixing – Monopsony – NCAA Amateurism – Student-Athlete Compensation – Education-Related Benefits – Joint Venture – Least Restrictive Means **Holding:** The Supreme Court unanimously affirmed the Ninth Circuit, upholding an injunction that struck down NCAA rules limiting education-related benefits (e.g., graduate scholarships, tutoring, paid internships) for Division I football and basketball players. The Court held that the NCAA’s compensation restrictions are subject to ordinary rule-of-reason analysis, not quick-look deference, because the NCAA exercises monopsony power and its horizontal price fixing produces significant anticompetitive effects. The Court rejected the NCAA’s arguments for antitrust immunity based on amateurism or its status as a joint venture, and found that the district court properly applied the rule of reason without imposing a least-restrictive-means test, instead requiring the NCAA to show that substantially less restrictive alternatives could not achieve the same procompetitive benefits. Justice Kavanaugh’s concurrence noted that the NCAA’s remaining compensation limits may face future antitrust scrutiny.

Holdings

1. The NCAA's compensation restrictions are subject to ordinary rule of reason scrutiny, not an abbreviated deferential review, because the NCAA has monopsony power and its restraints are not obviously procompetitive.
2. The district court did not require a least restrictive means test; it only found the NCAA's restraints 'patently and inexplicably stricter than is necessary' after finding that the NCAA failed to prove procompetitive benefits.
3. The district court did not impermissibly redefine the product; it applied the rule of reason and found that the NCAA had not maintained a consistent definition of amateurism and that the challenged restraints were not necessary to preserve consumer demand.
4. The district court's injunction is proper and modest; it only enjoins education-related compensation restrictions and leaves the NCAA considerable flexibility, consistent with the principles of judicial restraint in antitrust remedies.

Questions Presented

1. Whether the NCAA's compensation restrictions should be subject to an abbreviated deferential review or ordinary rule of reason analysis.
2. Whether the district court erred by requiring the NCAA to prove that its rules are the least restrictive means of achieving procompetitive purposes.
3. Whether the district court impermissibly redefined the NCAA's product by rejecting its definition of amateurism.
4. Whether the district court's injunction is proper and not overly intrusive.

Disposition

affirmed