Haywood v. National Basketball Association
Encyclopedia
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 old requirement that a player may not be drafted by a NBA team unless he waited four years (which meant playing at the college level in most cases) following his graduation from high school.
turned pro after his sophomore season at the University of Detroit
, joining the American Basketball Association
’s 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 punitive sanctions against the SuperSonics.
. 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:
The NBA appealed to the Ninth Circuit Court of Appeals
, which stayed the injunction. Haywood, joined by the Sonics, then 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.
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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1971), was a U.S. Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that ruled, 7–2, against the National Basketball Association
National Basketball Association
The National Basketball Association is the pre-eminent men's professional basketball league in North America. It consists of thirty franchised member clubs, of which twenty-nine are located in the United States and one in Canada...
’s old requirement that a player may not be drafted by a NBA team unless he waited four years (which meant playing at the college level in most cases) following his graduation from high school.
Background
Spencer HaywoodSpencer Haywood
Spencer Haywood is a retired American professional basketball player.- High school :In 1964, Haywood moved to Detroit, Michigan, where he attended Pershing High School...
turned pro after his sophomore season at the University of Detroit
Detroit Titans men's basketball
The Detroit Titans team is the basketball team that represents the University of Detroit Mercy in Detroit, Michigan, USA. The school's team currently competes in the Horizon League. The team last played in the NCAA Division I Men's Basketball Tournament in 1999...
, joining the American Basketball Association
American Basketball Association
The American Basketball Association was a professional basketball league founded in 1967. The ABA ceased to exist with the ABA–NBA merger in 1976.-League history:...
’s 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
Seattle SuperSonics
The Seattle SuperSonics were an American professional basketball team based in Seattle, Washington that played in the Pacific and Northwest Divisions of the National Basketball Association from 1967 until 2008. Following the 2007–08 season, the team relocated to Oklahoma City, and now plays as...
owner Sam Schulman
Sam Schulman
Samuel "Sam" Schulman was an American businessman from New York who was a founding owner and President of the Seattle SuperSonics of the National Basketball Association and an owner of the San Diego Chargers of the National Football League.Born April 10, 1910, in New York City, Schulman graduated...
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 punitive 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 ActSherman Antitrust Act
The Sherman Antitrust Act requires the United States federal government to investigate and pursue trusts, companies, and organizations suspected of violating the Act. It was the first Federal statute to limit cartels and monopolies, and today still forms the basis for most antitrust litigation by...
. 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
United States District Court for the Central District of California
The United States District Court for the Central District of California serves over 18 million people in southern and central California, making it the largest federal judicial district by population...
, which issued an injunction
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
in Haywood's favor, ruling:
The NBA appealed to the Ninth Circuit Court of Appeals
United States Court of Appeals for the Ninth Circuit
The United States Court of Appeals for the Ninth Circuit is a U.S. federal court with appellate jurisdiction over the district courts in the following districts:* District of Alaska* District of Arizona...
, which stayed the injunction. Haywood, joined by the Sonics, then 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.The decision allowed a significant number of high school graduates and college attendees to make themselves eligible for the NBA Draft
NBA Draft
The NBA Draft is an annual event in which the thirty teams from the National Basketball Association can draft players who are eligible and wish to join the league. These players are usually amateur U.S. college basketball players, but international players are also eligible to be drafted...
before completing four years in college.
See also
- List of United States Supreme Court cases, volume 401
- Toolson v. New York YankeesToolson v. New York YankeesToolson v. New York Yankees is a 1953 U.S. Supreme Court decision that upheld, 7–2, the antitrust exemption first granted to Major League Baseball three decades earlier in Federal Baseball Club v. National League...
, - Silver v. New York Stock ExchangeSilver v. New York Stock ExchangeSilver v. New York Stock Exchange, , was a case of the United States Supreme Court which was decided May 20, 1963. It held that the duty of self-regulation imposed upon the New York Stock Exchange by the Securities Exchange Act of 1934 did not exempt it from the antitrust laws nor justify it in...
, - Brown v. Pro Football, Inc.,
- Clarett v. National Football League, 369 F.3d 124 (2d Cir. 2004)