The financial expansion of the N.F.L. has been accompanied by the promulgation of league rules to ensure league stability. These rules include several player service market restraints, which have been adopted by the N.F.L. to ensure competitive equality between the franchises. This note analyzes the validity of these restraints under the Sherman Antitrust Act in light of the recent decision of the District of Columbia Circuit Court of Appeals in Smith v. Pro Football, Inc. and presents a new approach to the economic structure of the N.F.L. which may validate the current restraints.
Note, The N.F.L.'s Final Victory over Smith v. Pro-Football, Inc.: Single Entity - Interleague Economic Analysis, 27 Clev. St. L. Rev. 541 (1978)