Defendant appealed the Superior Court of San Diego County (California) judgment awarding plaintiff damages under the Cartwright Act, Cal. Bus. & Prof. Code § 16700 et seq., in plaintiff’s antitrust action.

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Overview

Plaintiff, a professional football player, sued defendant, a member of the National Football League (NFL), for antitrust violations under the Cartwright Act, Cal. Bus. & Prof. Code § 16700 et seq., based on several operating rules of the NFL. The court awarded plaintiff damages, holding that defendants violated California antitrust law. On appeal, the court reversed with respect to judgment for plaintiff based on Cartwright Act, § 16700 et seq., antitrust violations. The court held that the Cartwright Act, § 16700 et seq., was inapplicable to the interstate activities of defendant since its application conflicted with the Commerce Clause. The court stated that a conflict existed because there was no strong state interest in applying the Cartwright Act, § 16700 et seq., and the extraterritorial effect on defendant and professional football would exact an impermissible burden on interstate commerce.

Outcome

Court reversed judgment for plaintiff on antitrust claims, because since state antitrust statutes impermissibly burdened interstate commerce, statutes were inapplicable to the interstate activities of defendant and professional football.