Haywood v. National Basketball Association

Haywood v. National Basketball Association, 401 U.S. 1204 (1971), was a U.S. Supreme Court decision that ruled, 7–2, against the National Basketball Association’s (NBA) old requirement that a player may not be drafted by an NBA team unless he waited four years (which meant playing at the college level in most cases) following his graduation from high school.

Haywood v. N.B.A.
Decided March 1, 1971
Full case nameIn re Spencer Haywood v. National Basketball Association
Citations401 U.S. 1204 (more)
91 S. Ct. 672; 28 L. Ed. 2d 206
Holding
Haywood was granted an injunction pendente lite which allowed him to play for Seattle and forbade the NBA to take sanctions against the Seattle team.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
Hugo Black · William O. Douglas
John M. Harlan II · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Case opinion
MajorityDouglas
Laws applied
Sherman Antitrust Act

Background

Spencer Haywood turned pro after his sophomore season at the University of Detroit, joining the American Basketball Association’s (ABA) Denver Rockets and leading the league in scoring (30.0 per game) and rebounding (19.5 per game) in 1969-70 before jumping to the NBA the following season. Seattle SuperSonics owner Sam Schulman signed Haywood to a six-year, $1.5 million contract, ignoring the rule that a player cannot join the league until he is four years out of high school. As a result, the NBA threatened to disallow the contract and implement various sanctions against the SuperSonics.

Procedural history

Haywood challenged this decision by commencing an antitrust action against the NBA. As part of his claim against the NBA, Haywood argued that the conduct of the NBA was a "group boycott" and a violation of the Sherman Antitrust Act. The central issue that had to be determined was whether the NBA draft policy was a restraint on trade and therefore was illegal in accordance with the Sherman Act.

The case was filed in the United States District Court for the Central District of California, which issued an injunction in Haywood's favor, ruling:

If Haywood is unable to continue to play professional basketball for Seattle, he will suffer irreparable injury in that a substantial part of his playing career will have been dissipated, his physical condition, skills, and coordination will deteriorate from lack of high-level competition, his public acceptance as a super star will diminish to the detriment of his career, his self-esteem, and his pride will have been injured and a great injustice will be perpetrated on him.

The NBA appealed to the Ninth Circuit Court of Appeals, which stayed the injunction. Joined by the SuperSonics, Haywood appealed to the Supreme Court, which upheld the District Court, reinstated that court's injunction against the NBA, and remanded the case to the District Court for further proceedings.

Impact

Shortly after the Supreme Court's decision, the league and Haywood reached an out-of-court settlement which allowed him to stay with the Sonics permanently.[1]

The decision allowed a significant number of high school graduates and college attendees to make themselves eligible for the NBA Draft before completing four years in college.

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See also

Further reading
  • Allison, John R. (1973). "Professional Sports and the Antitrust Laws: Status of the Reserve System". Baylor Law Review. XXV (1).
  • Wise, Aaron N.; Meyer, Bruce S. (1997). International Sports Law and Business. New York: Kluwer Law International. pp. 47–48. ISBN 90-411-0977-3.

Notes and references
  1. Friedman, David (2005-04-18). "Excerpt, "Chocolate Thunder and Short Shorts: The NBA in the 1970s"". Basketball in America: From the Playgrounds to Jordan's Game and Beyond. Archived from the original on 2008-09-08. Retrieved 2008-11-13.
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