Sullivan v. National Football

Case Date: 09/29/1994
Court: United States Court of Appeals
Docket No: 94-1031


September 29, 1994

UNITED STATES COURT OF APPEALS

FOR THE FIRST CIRCUIT

No. 94-1031

WILLIAM H. SULLIVAN II,

Plaintiff - Appellee,

v.

PAUL TAGLIABUE, ET AL.,

Defendants -Appellees.

____________________

NATIONAL FOOTBALL LEAGUE, &

MEMBERS OF THE NATIONAL FOOTBALL LEAGUE

Defendants - Appellants.

____________________

ERRATA SHEET

The opinion of this Court issued on September 16, 1994, is

amended as follows:

The caption on the coversheet should read: "William H.

Sullivan II, Plaintiff - Appellee v. National Football League, &

Members of the National Football League." "Paul Tagliabue, et

al., Defendants - Appellees" should be deleted.



UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________

No. 94-1031

WILLIAM H. SULLIVAN II,
Plaintiff - Appellee,

v.

NATIONAL FOOTBALL LEAGUE, &
MEMBERS OF THE NATIONAL FOOTBALL LEAGUE
Defendants - Appellants.

____________________

APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Edward F. Harrington, U.S. District Judge]
___________________

____________________

Before

Torruella, Circuit Judge,
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Coffin, Senior Circuit Judge,
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and Stahl, Circuit Judge.
_____________

_____________________

John Vanderstar, with whom Sonya D. Winner, Ethan M. Posner,
_______________ _______________ _______________
Covington & Burling, Jeremiah T. O'Sullivan, Sarah Chapin
_____________________ ________________________ ______________
Columbia, Choate, Hall & Stewart, Joseph W. Cotchett, and
________ _________________________ ____________________
Cotchett, Illston & Pitre were on brief for appellants.
_________________________
Joseph L. Alioto and Frederick P. Furth, with whom Angela M.
________________ __________________ _________
Alioto, Law Offices of Joseph L. Alioto, Alan R. Hoffman, Lynch,
______ _______________________________ _______________ ______
Brewer, Hoffman & Sands, Bruce J. Wecker, Michael P. Lehmann and
________________________ _______________ __________________
Furth, Fahrner & Mason, were on brief for appellees.
______________________
____________________

September 16, 1994
____________________



TORRUELLA, Circuit Judge. The National Football League
_____________

and twenty-one organizations owning NFL franchises (referred to

collectively as the "NFL") appeal the judgment entered against

them after a jury found that the NFL violated the antitrust laws

by restricting owners of member football clubs from selling

shares in their teams to the public. Plaintiff-appellee, William

H. Sullivan, former owner of the New England Patriots football

team (the "Patriots"), was awarded a total of $51 million in

damages for the losses Sullivan incurred when he had to sell the

Patriots to a private buyer after the NFL prevented him from

offering 49% of the team to the public in the form of publicly

traded stock. Because several prejudicial errors were committed

during the trial, we vacate the judgment and remand for a new

trial.

I. BACKGROUND
I. BACKGROUND

Under Article 3.5 of the NFL's constitution and by-

laws, three-quarters of the NFL club owners must approve all

transfers of ownership interests in an NFL team, other than

transfers within a family. In conjunction with this rule is an

uncodified policy against the sale of ownership interests in an

NFL club to the public through offerings of publicly traded

stock. The members, however, retain full authority to approve

any given transfer by a three-quarters vote according to Article

3.5.

Sullivan owned the Patriots from the team's inception

in 1959 until October of 1988. When Sullivan formed the
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Patriots, he and his partner sold non-voting shares of the team

to the public beginning in 1960. At that time, the Patriots were

in the old American Football League ("AFL"), which was separate

from the NFL, and which had no policy against public ownership of

teams. In 1966, the AFL and the old NFL merged into a single

league. Under the terms of the merger, the new NFL would adopt

the old NFL's policy against public ownership. The Patriots,

however, were allowed to retain their level of public ownership

as a special exception to the rule under a grandfather clause.

In 1976, Sullivan sought to acquire the publicly held

shares of the Patriots through a merger of the club into a new

Sullivan-owned company. Stockholders approved the transfer and

the transaction was subsequently consummated, although some

shareholders subsequently brought suit, challenging the

sufficiency of the purchase price. After protracted litigation,

the shareholders obtained a judgment requiring Sullivan to pay

them a higher price for their shares. The Patriots then became a

fully privately owned club.

Sullivan and his son, Chuck Sullivan, who owned the

stadium where the Patriots played, began to experience financial

difficulties and increasing debt burdens in the mid-1980s. The

Sullivans decided that they needed to raise capital to alleviate

their financial problems. After the Boston Celtics professional

basketball franchise made a public offering of 40% of the team in

December of 1986, the Sullivans decided to pursue a similar deal

with the Patriots in order to raise cash to cover some of their
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debts.

On October 19, 1987, the Sullivans met with Stephens,

Inc., a small investment banking firm in Little Rock, Arkansas.

They discussed a debt financing deal whereby Stephens would loan

the Sullivans $80 million dollars, with half going to the

Patriots and the other half to Chuck Sullivan's company which

owned the Patriots' stadium. The Patriots' portion of the loan

would be repaid out of the proceeds of the sale of 49% of the

Patriots through the offering of public stock. Stephens agreed

to look into the possibility of arranging the deal, but informed

the Sullivans that they would first have to get NFL approval.

Sullivan ultimately never obtained NFL approval and the deal with

Stephens never progressed beyond some preliminary discussions.

At a meeting of the NFL owners on October 27, 1987,

Sullivan raised his stock sale idea with the other owners and

asked for a modification of the NFL's policy against public

ownership to allow for certain controlled sales of minority

interests in NFL clubs. Alternatively, Sullivan requested a

waiver from the public ownership policy for his contemplated

public offering of the Patriots. Sullivan's request was

eventually tabled at this meeting. Discussions continued among

the owners and, at one point, Sullivan counted 17 of the 21

owners needed for approval as being in favor of allowing him to

make his public offering (seven owners were still undecided).

Pete Rozelle, NFL Commissioner at the time, told Sullivans that

he was not in favor of Sullivan's proposals and that league
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approval was "very dubious." Sullivan ultimately never asked for

a vote on amending the ownership policy or on waiving the policy

for the Patriots, and the NFL never held such a vote. Sullivan

claims that he did not ask for a vote because it would have been

futile.

In October of 1988, Sullivan sold the Patriots for

approximately $83.7 million to KMS Patriots L.P. ("KMS"), a

limited partnership owned by Victor Kiam and Francis Murray.

Sullivan alleges that, absent the NFL's public ownership policy,

he would have been able to retain a majority share of a rapidly

appreciating asset with a high potential for future profits.

Instead, Sullivan asserts, he was forced to sell the Patriots at

a depressed price to private buyers.

On May 16, 1991, Sullivan sued the NFL claiming that,

among other things, the NFL had violated the Sherman Antitrust

Act, 15 U.S.C. 1-2, by preventing him from selling 49% of the

Patriots to the public in an equity offering. Sullivan alleged

that, as a result, he was forced to sell the entire team to a

private buyer at a fire sale price in order to pay off existing

debts. Prior to trial, the district court dismissed Sullivan's

claim under 2 of the Sherman Act along with various state law

claims. After a trial on Sullivan's claim under 1 of the

Sherman Act, the jury rendered a verdict for Sullivan in the

amount of $38 million, which the judge later reduced through

remittitur to $17 million. Pursuant to 15 U.S.C. 15, which

provides for treble damages for antitrust violations, the court
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entered a final judgment for Sullivan of $51 million.






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II. ANALYSIS
II. ANALYSIS

The NFL has raised a number of issues on appeal

concerning the application of 1 of the Sherman Act to the facts

of this case, which, according to the NFL, entitle it to judgment

as a matter of law. We address these issues first to see if the

present case should be dismissed, and we ultimately conclude that

it should not. We next address the NFL's allegations of trial

error and we find that several of them require that we overturn

the verdict in this case and order a new trial.

The first set of issues involves the district court's

denial of the NFL's motions for judgment as a matter of law under

Fed. R. Civ. P. 50. We review the court's decision de novo,
_______

using the same stringent decisional standards that controlled the

district court. Gallagher v. Wilton Enterprises, Inc., 962 F.2d
_________ _________________________

120, 125 (1st Cir. 1992); Hendricks & Assocs., Inc. v. Daewoo
__________________________ ______

Corp., 923 F.2d 209, 214 (1st Cir. 1991). Under these standards,
_____

judgment for the NFL can only be ordered if the evidence, viewed

in the light most favorable to Sullivan, points so strongly and

overwhelmingly in favor of the NFL, that a reasonable jury could

not have arrived at a verdict for Sullivan. Gallagher, 962 F.2d
_________

at 124-25; Hendricks, 923 F.2d at 214.
_________

III. ISSUES ALLEGEDLY REQUIRING JUDGMENT FOR THE NFL
III. ISSUES ALLEGEDLY REQUIRING JUDGMENT FOR THE NFL

A. Lack of Antitrust Injury
A. Lack of Antitrust Injury

To establish an antitrust violation under 1 of the

Sherman Act, Sullivan must prove that the NFL's public ownership

policy is "in restraint of trade." Monahan's Marine, Inc. v.
_______________________
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Boston Whaler, Inc., 866 F.2d 525, 526 (1st Cir. 1989). Under
___________________

antitrust law's "rule of reason," the NFL's policy is in

restraint of trade if the anticompetitive effects of the policy

outweigh the policy's legitimate business justifications. Id. at
__

526-27 (citing Business Electronics Corp. v. Sharp Electronics
__________________________ __________________

Corp., 485 U.S. 717, 723 (1988)). Anticompetitive effects, more
_____

commonly referred to as "injury to competition" or "harm to the

competitive process," are usually measured by a reduction in
_____________

output and an increase in prices in the relevant market.
______ ____________________

National Collegiate Athletic Ass'n v. Board of Regents of Univ.
___________________________________ __________________________

of Okla., 468 U.S. 85, 104-07 (1984) ("Restrictions on price and
_________

output are the paradigmatic examples of restraints of trade")

(hereinafter "NCAA"); Chicago Professional Sports Ltd.
____ _______________________________________

Partnership v. National Basketball Association, 961 F.2d 667, 670
___________ _______________________________

(7th Cir.), cert. denied, 113 S. Ct. 409 (1992). Injury to
____ ______

competition has also been described more generally in terms of

decreased efficiency in the marketplace which negatively impacts
____________________

consumers. Town of Concord v. Boston Edison Co., 915 F.2d 17,
_______________ _________________

21-22 (1st Cir. 1990), cert. denied, 499 U.S. 931 (1991);
____ ______

Interface Group, Inc. v. Massachusetts Port Auth., 816 F.2d 9, 10
_____________________ ________________________

(1st Cir. 1987). Thus, an action harms the competitive process

"when it obstructs the achievement of competition's basic goals -

- lower prices, better products, and more efficient production

methods." Town of Concord, 915 F.2d at 22.
_______________

The jury determined in this case, via a special verdict

form, that the relevant market is the "nationwide market for the
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sale and purchase of ownership interests in the National Football

League member clubs, in general, and in the New England Patriots,

in particular." The jury went on to find that the NFL's policy

had an "actual harmful effect" on competition in this market.

The NFL argues on appeal that Sullivan has not

established the existence of any injury to competition, and thus

has not established a restraint of trade that can be attributed

to the NFL's ownership policy. The league's attack is two-fold,

asserting (1) that NFL clubs do not compete with each other for

the sale of ownership interests in their teams so there exists no

competition to be injured in the first place; and (2) Sullivan

did not present sufficient evidence of injury to competition from

which a reasonable jury could conclude that the NFL's policy

restrains trade. Although we agree with the NFL that

conceptualizing the harm to competition in this case is rather

difficult, precedent and deference to the jury verdict ultimately

require us to reject the NFL's challenge to the finding of injury

to competition.

Critically, the NFL does not challenge on appeal the
___

jury's initial finding of the relevant market and no

corresponding challenge was raised at trial.1 As a result, the

____________________

1 The NFL argues in passing that certain expert testimony
related to the relevant market issue was inherently unreasonable
and thus could not support the jury's relevant market finding.
We do not consider this passing argument to be sufficient to
raise the relevant market issue on appeal as matters averted to
in a perfunctory manner, unaccompanied by some effort at
developed argumentation, are deemed waived on appeal. United
______
States v. Innamorati, 996 F.2d 456, 468 (1st Cir. 1993). More
______ __________
importantly, the NFL did not challenge the relevant market issue

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NFL faces an uphill battle in its attack on the presence of an

injury to competition. Given the existence of a relevant market

for ownership interests in NFL teams, it is reasonable to presume

that a policy restricting the buying and selling of such

ownership interests injures competition in that market. The NFL

nevertheless maintains that NFL teams do not compete against each

other for the sale of their ownership interests, even if we

accept that a market exists for such ownership interests.

1. No Competition Subject to Injury as Matter of Law
1. No Competition Subject to Injury as Matter of Law
_________________________________________________

The NFL correctly points out that member clubs must

cooperate in a variety of ways, and may do so lawfully, in order

to make the football league a success. See United States
___ ______________

Football League v. National Football League, 842 F.2d 1335, 1372
_______________ ________________________

(2d Cir. 1988); Los Angeles Memorial Coliseum Comm'n v. National
_____________________________________ ________

Football League, 726 F.2d 1381, 1391-92 (9th Cir.), cert. denied,
_______________ ____ ______

469 U.S. 990 (1984) (hereinafter "L.A. Coliseum"); North American
_____________ ______________

Soccer League v. National Football League, 670 F.2d 1249, 1251
______________ _________________________

(2d Cir.), cert. denied, 459 U.S. 1074 (1982) (hereinafter
____ ______

"NASL"). On the other hand, it is well established that NFL
____

clubs also compete with each other, both on and off the field,

for things like fan support, players, coaches, ticket sales,

local broadcast revenues, and the sale of team paraphernalia.

Mid-South Grizzlies v. National Football League, 720 F.2d 772,
___________________ _________________________


____________________

in either its directed verdict motion or in its motion for
judgment as a matter of law. We will not consider arguments
which could have been, but were not, advanced below. Domegan v.
_______
Fair, 859 F.2d 1059, 1065 (1st Cir. 1988).
____

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786-87 (3d Cir. 1983), cert. denied, 467 U.S. 1215 (1984); L.A.
____ ______ ____

Coliseum, 726 F.2d at 1390, 1393, 1395, 1397. The question of
________

whether competition exists between NFL teams for sale of their

ownership interests, such that the NFL's ownership policy injures

this competition, is ultimately a question of fact. The NFL

would have us find, however, that, as a matter of law, NFL teams

do not compete against each other for the sale of their ownership

interests. We decline to make such a finding.

The NFL relies on a series of cases which allegedly

stand for the "well established" rule that a professional sports

league's restrictions on who may join the league or acquire an

interest in a member club do not give rise to a claim under the

antitrust laws. Seattle Totems Hockey Club, Inc. v. National
__________________________________ ________

Hockey League, 783 F.2d 1347 (9th Cir.), cert. denied, 479 U.S.
_____________ ____ ______

932 (1986); Fishman v. Estate of Wirtz, 807 F.2d 520 (7th Cir.
_______ ________________

1986); Mid-South Grizzlies, 720 F.2d at 772; Levin v. National
___________________ _____ ________

Basketball Ass'n, 385 F. Supp. 149 (S.D.N.Y. 1974). These cases,
________________

all involving a professional sport's league's refusal to approve

individual transfers of team ownership or the creation of new

teams, do not stand for the broad proposition that no NFL

ownership policy can injure competition. See, e.g., NASL, 670
___ ____ ____

F.2d at 1259-61 (finding that the NFL's policy against cross-

ownership of NFL teams and franchises in competing sports

leagues, which also effectively barred certain owners who owned

other sports franchises from purchasing NFL teams, injured

competition between the NFL and competing sports leagues and thus
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violated 1 of the Sherman Act).

None of the cases cited by the NFL considered the

particular relevant market that was found by the jury in this

case or a league policy against public ownership. Seattle Totems
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and Mid-South Grizzlies considered potential inter-league
_____________________ _____

competition when a sports league rejected plaintiffs'

applications for new league franchises. Seattle Totems, 783 F.2d
______________

at 1349-50; Mid-South Grizzlies, 720 F.2d at 785-86. Those
____________________

decisions found no injury to competition because the plaintiffs

were not competing with the defendant sports leagues, but rather,

were seeking to join those leagues. Seattle Totems, 783 F.2d at
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1350; Mid-South Grizzlies, 720 F.2d at 785-86. Mid-South
____________________ _________

Grizzlies left open the possibility that potential intra-league
_________ _____

competition between NFL football clubs could be harmed by the

NFL's action, but found that the plaintiff in that case had not

presented sufficient evidence of harm to such competition. Mid-
____

South Grizzlies, 720 F.2d at 786-87.
_______________

The Fishman and Levin cases concerned the National
_______ _____

Basketball Association's ("N.B.A.") rejection of plaintiffs'

attempts to buy an existing team. Fishman, 807 F.2d at 525-31;
_______

Levin, 385 F. Supp. at 150-51. Those cases also based their
_____

finding that there was no injury to competition on the fact that

the plaintiffs were seeking to join with, rather than compete

against, the N.B.A. Fishman, 807 F.2d at 544; Levin, 385 F.
_______ _____

Supp. at 152. Neither case considered whether competition

between teams for investment capital was injured. As pointed out
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in Piazza v. Major League Baseball, 831 F. Supp. 420 (E.D.Pa.
______ ______________________

1993), Fishman explicitly recognized the potential for
_______

competition in the market for ownership of teams, although the

plaintiff had failed to raise the issue, and Levin simply
_____

presumed, incorrectly, that there could never be any competition

among league members. Piazza, 831 F. Supp. at 430-31 & n.16
______

(citing Fishman, 807 F.2d at 532 n.9; and Levin, 385 F. Supp. at
_______ _____

152).

The important distinction to make between the cases

cited by the NFL and the present case is that here Sullivan

alleges that the NFL's policy against public ownership generally

restricts competition between clubs for the sale of their

ownership interests, whereas in the aforementioned cases, a

league's refusal to approve a given sale transaction or a new

team merely prevented particular outsiders from joining the

league, but did not limit competition between the teams

themselves. To put it another way, the NFL's public ownership

policy allegedly does not merely prevent the replacement of one

club owner with another -- an action having little evident effect

on competition -- it compromises the entire process by which

competition for club ownership occurs.2

____________________

2 This same argument distinguishes cases cited by the NFL for
the proposition that a franchisor's disapproval of a proposed
sale of a franchise does not give rise to an antitrust injury.
See Kestenbaum v. Falstaff Brewing Corp., 514 F.2d 690 (5th Cir.
___ __________ ______________________
1975), cert. denied, 424 U.S. 943 (1976); McDaniel v. General
____ ______ ________ _______
Motors Corp., 480 F. Supp. 666 (E.D.N.Y. 1979). Individual
_____________
decisions to block the sale of a franchise do not implicate the
harm to competition that is caused by a policy restricting all
sales of a certain type of ownership interest. Only the broad-

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We take a moment to briefly address a related argument

raised by the NFL to the effect that NFL clubs are unable to

conspire with each other under 1 of the Sherman Act because

they function as a single enterprise in relation to the league's

public ownership policy. The NFL asserts that the Supreme

Court's holding in Copperweld Corp. v. Independence Tube Corp.,
________________ _______________________

467 U.S. 752 (1984), controls the facts of this case and

overturns prior caselaw holding that NFL clubs do not constitute

a single enterprise but rather, are separate entities which were

capable of conspiring with each other under 1. See L.A.
___ ____

Coliseum, 726 F.2d at 1387-90; NASL, 670 F.2d at 1256-58.
________ ____

We do not agree that Copperweld, which found a
__________

corporation and its wholly owned subsidiary to be a single

enterprise for purposes of 1, Copperweld, 467 U.S. at 771,
__________

applies to the facts of this case or affects the prior precedent

concerning the NFL. See McNeil v. National Football League, 790
___ ______ ________________________

F. Supp. 871, 879-80 (D.Minn. 1992) (holding that Copperweld did
__________

not apply to the NFL and its member clubs and finding the clubs

to be separate entities capable of conspiring together under

1). Copperweld's holding turned on the fact that the subsidiary
__________

of a corporation, although legally distinct from the corporation

itself, "pursue[d] the common interests of the whole rather than

interests separate from those of the corporation itself."

Copperweld, 467 U.S. at 770. As emphasized in City of Mt.
__________ ____________

____________________

based policy has the potential to compromise the entire
competitive process for the buying and selling of a good in a
relevant market.

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Pleasant, Iowa v. Associated Elec. Co-op., Inc., 838 F.2d 268
_______________ ______________________________

(8th Cir. 1988), upon which the NFL relies for the application of

Copperweld to this case, the critical inquiry is whether the
__________

alleged antitrust conspirators have a "unity of interests" or

whether, instead, "any of the defendants has pursued interests

diverse from those of the cooperative itself." Id. at 274-77
__

(defining "diverse" as "interests which tend to show that any two

of the defendants are, or have been, actual or potential

competitors"). As we have already noted, NFL member clubs

compete in several ways off the field, which itself tends to show

that the teams pursue diverse interests and thus are not a single

enterprise under 1.

Ultimately, the NFL's Copperweld challenge is subsumed
__________

under the question of whether or not the evidence can support a

finding that NFL teams compete against each other for the sale of

their ownership interests. Proof of such competition defeats

both the NFL's challenge to the existence of an injury to

competition and the NFL's Copperweld argument as well.
__________

Insufficient proof of such competition would require a judgment

in favor of the NFL anyway, regardless of the implications under

Copperweld. As we discuss below, the jury's finding that there
__________

exists competition between teams for the sale of ownership

interests was based on sufficient evidence.

2. Insufficient Evidence of Harm to Competition
2. Insufficient Evidence of Harm to Competition
____________________________________________

The NFL contends that Sullivan did not present

sufficient evidence concerning: (1) the existence of competition
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between NFL clubs for the sale of ownership interests, or (2) a

decrease in output, an increase in prices, a detrimental effect

on efficiency or other incidents of harm to competition in the

relevant market, from which a reasonable jury could conclude that

the NFL's policy injured competition. Although we agree that the

evidence of all these factors is rather thin, we disagree that

the evidence is too thin to support a jury verdict in Sullivan's

favor.

With respect to evidence of the existence of

competition for the sale of ownership interests, one of

Sullivan's experts, Professor Roger Noll, testified that "one of

the ways in which the NFL exercises monopoly power in the market

for the franchises and ownership is by excluding certain people

from owning all or part -- any type part of an NFL franchise."

Dr. Noll explained that this "enables a group of owners, in this

case, you only need eight owners, to exclude from the League and

from competing with them, people who might be more effective

competitors than they are." The record also contains statements

from several NFL owners which could reasonably be interpreted as

expressions of concern about their ability to compete with other

teams in the market for investment capital in general, and for

the sale of ownership interests in particular. For example,

Arthur Rooney II of the Pittsburgh Steelers stated in a letter

that he did not "believe that the individually or family owned

teams will be able to compete with the consolidated groups."

Ralph Wilson of the Buffalo Bills stated that big corporations
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should not own teams because it gives them an "unfair competitive

advantage" over other teams since corporations will funnel money

into the team and make it "more competitive" than the other

franchises. Former NFL Commissioner Pete Rozelle admitted that

similar sentiments had been expressed by NFL members.

Although it is not precisely clear that the

"competition" about which Noll, Rooney, and Wilson were

discussing is the same competition at issue here -- that is

competition for the sale of ownership interests -- a jury could

reasonably interpret these statements as expressing a belief that

the competition exists between teams for the sale of ownership

interests. The statements of the two NFL owners imply that

greater access to capital for all teams will put increased

pressure on some teams to compete with others for that capital,

and all the statements reveal that the ownership rules,

particularly the rule against public ownership, is the main

obstacle preventing such access. The fact that ownership by

"consolidated groups" is not necessarily the same as public

ownership does not affect the conclusion that teams face

competitive pressure in selling their ownership interests

generally to whoever might buy them. We also note that evidence

of actual, present competition is not necessary as long as the

evidence shows that the potential for competition exists. See L.
___ __

A. Coliseum, 726 F.2d at 1394 (discussing significance of
____________

potential competition, especially where challenged policy limits
_________

such competition so that it is not evident in practice). It
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would be difficult indeed to provide direct evidence of

competition when the NFL effectively prohibits it.

The NFL focusses on the fact that Professor Noll

testified that many of the purchasers of Patriots' stock would be

New England sports fans and others in the New England area. The

NFL points out that other NFL teams would not compete with the

Patriots for the sale of stock to their own fans. This argument

slightly distorts Professor Noll's testimony. Professor Noll

stated that local souvenir buyers would be one portion of the

market for Patriots stock. Professor Noll also testified several

times that other investors would buy Patriots stock as well, for

investment purposes. Noll's point was that the souvenir buyers

would serve to bid up the price of the stock above what the price

would normally be if the Patriots were a regular company. His

testimony did not preclude a finding that NFL teams compete

against each other for investment capital via the sale of

ownership interests.

The record also contains sufficient evidence of the

normal incidents of injury to competition from the NFL's policy -

- reduced output, increased prices, and reduced efficiency -- to

support the jury's verdict. As Dr. Noll pointed out in his

testimony, the NFL's policy "excludes individuals . . . who might

want to own a share of stock in a professional football team."

Several NFL officials themselves admitted that the policy

restricts the market for investment capital among NFL teams.

There is thus little dispute that the NFL's ownership policy
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reduces the available output of ownership interests.

The NFL is correct that, in one sense, the overall pool

of potential output is fixed because there are only 28 NFL teams

and, although their value may fluctuate, the quantity of their

ownership interests cannot. However, the NFL's public ownership

policy completely wipes out a certain type of ownership interest

-- public ownership of stock. By restricting output in one form
____

of ownership, the NFL is thereby reducing the output of ownership

interests overall. In other words, the NFL is literally

restricting the output of a product -- a share in an NFL team.

There was considerable testimony concerning the price

effects of the NFL policy. Both of Sullivan's experts testified

that the policy depressed the price of ownership interests in NFL

teams because NFL franchises would normally command a premium on

the public market relative to their value in the private market,

which is all that the league currently permits. Professor Noll

testified that fan loyalty would push up the price of ownership

interests if sales to the public were allowed. Even former

Commissioner Pete Rozelle acknowledged that "it was pointed out,

with justification, it has been over the years, that [the

ownership policy] does restrict your market and, very likely, the

price you could get for one of our franchises if you wanted to

sell it, because you are eliminating a very broad market . . . .

And they have said that there is a depression on the price they

could get for their franchise."

The NFL points out that the alleged effect of its
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ownership policy is to reduce prices of NFL team ownership
______

interests, rather than to raise prices which is normally the

measure of an injury to competition. E.g., Town of Concord, 915
____ _______________

F.2d at 22. We acknowledge that it is not clear whether, absent

some sort of dumping or predatory pricing, see, e.g., Monahan's
___ ____ _________

Marine, Inc. v. Boston Whaler, Inc., 866 F.2d 525, 527 (1st Cir.
____________ ___________________

1989), a decrease in prices can indicate injury to competition in

a relevant market. The Supreme Court has emphasized, however,

that overall consumer preferences in setting output and prices is

more important than higher prices and lower output, per se, in
______

determining whether there has been an injury to competition.

NCAA, 468 U.S. at 107. In this case, regardless of the exact
____

price effects of the NFL's policy, the overall market effects of

the policy are plainly unresponsive to consumer demand for

ownership interests in NFL teams. Dr. Noll testified that fans

are interested in buying shares in NFL teams and that the NFL's

policy deprives fans of this product. Moreover, evidence was

presented concerning the public offering of the Boston Celtics

professional basketball team which demonstrated, according to

some of the testimony, fan interest in buying ownership of

professional sports teams. Thus, a jury could conclude that the

NFL's policy injured competition by making the relevant market

"unresponsive to consumer preference." Id.3
__

____________________

3 The NFL maintains that price and output are not affected
because its ownership policy does not limit the number of games
or teams, does not raise ticket prices or the prices of game
telecasts and does not affect the normal consumer of the NFL's
product in any other way. Such facts might be relevant to an

-20-


As for overall efficiency of production in the relevant

market,4 Sullivan's experts testified that the NFL's policy

hindered efficiency gains, and that allowing public ownership

would make for better football teams. Professor Noll stated that

the NFL's public ownership policy prevented individuals who might

be "more efficient and much better at running a professional

football team" from owning teams. Dr. Noll also stated that

publicly owned NFL teams would be better managed, and produce

higher quality entertainment for the fans. Noll testified that

the ownership rule excluded certain types of management

structures which would likely be more efficient in running the

teams, resulting in higher franchise values. One NFL owner,

Lamar Hunt, acknowledged that increased access to capital can

improve a team's operations and performance. A memorandum

prepared by an NFL staff member stated that changes to the NFL's


____________________

inquiry of whether the NFL's policy harms overall efficiency, see
___
infra note [4], but it is not relevant to whether the policy
_____
affects output and prices in the relevant market for ownership
_______________________
interests. Just because consumers of "NFL football" are not
affected by output controls and price increases does not mean
that consumers of a product in the relevant market are not so
affected. In this case, two types of consumers are denied
products by the NFL policy: consumers who want to buy stock of
the Patriots or other teams, and consumers like Sullivan who want
to "purchase" investment capital in the market for public
financing.

4 Although the product at issue in the relevant market is
"ownership interests," efficiency in production of that product
can be measured by the value of the ownership interest. That is,
an improved product produced more efficiently will be reflected
in the value of the output in question (regardless of the price).
In this case, the value of the product depends on the success of
the Patriots' football team, the overall efficiency of its
operations, and the success of the NFL in general.

-21-


public ownership policy could contribute to each NFL team's own

financial strength and viability, which in turn would benefit the

entire NFL because the league has a strong interest in having

strong, viable teams.

The NFL presented a large amount of evidence to the

contrary and now claims on appeal that Sullivan's position was

based on nothing more than sheer speculation. We have reviewed

the record, however, and we cannot say that the evidence was so

overwhelming that no reasonable jury could find against the NFL

and in favor of Sullivan. We therefore refuse to enter judgment

in favor of the NFL as a matter of law.

B. Ancillary Benefits
B. Ancillary Benefits

The NFL next argues that even if its public ownership

policy injures competition in a relevant market, it should be

upheld as ancillary to the legitimate joint activity that is "NFL
_________

football" and thus not violative of the Sherman Act. We take no

issue with the proposition that certain joint ventures enable

separate business entities to combine their skills and resources

in pursuit of a common goal that cannot be effectively pursued by

the venturers acting alone. See, e.g., Broadcast Music, Inc. v.
___ ____ _____________________

Columbia Broadcasting System, Inc., 441 U.S. 1 (1979). We also
__________________________________

do not dispute that a "restraint" that is ancillary to the

functioning of such a joint activity -- i.e. one that is required

to make the joint activity more efficient -- does not necessarily

violate the antitrust laws. Broadcast Music, 441 U.S. at 23-25;
_______________

Rothery Storage & Van Co. v. Atlas Van Lines, Inc., 792 F.2d 210,
_________________________ _____________________
-22-


at 223-24 (D.C. Cir. 1986), cert. denied, 479 U.S. 1033 (1987);
____ ______

see also Northwest Wholesale Stationers, Inc. v. Pacific
_________ _______________________________________ _______

Stationery & Printing Co., 472 U.S. 284, 295-96 (1985). We
___________________________

further accept, for purposes of this appeal, that rules

controlling who may join a joint venture can be ancillary to a

legitimate joint activity and that the NFL's own policy against

public ownership constitutes one example of such an ancillary
______

rule. Finally, we accept the NFL's claim that its public

ownership policy contributes to the ability of the NFL to

function as an effective sports league, and that the NFL's

functioning would be impaired if publicly owned teams were

permitted, because the short-term dividend interests of a club's

shareholder would often conflict with the long-term interests of

the league as a whole. That is, the policy avoids a detrimental

conflict of interests between team shareholders and the league.

We disagree, however, that these factors are sufficient

to establish as a matter of law that the NFL's ownership policy

does not unreasonably restrain trade in violation of 1 of the

Sherman Act. The holdings in Broadcast Music, Rothery Storage,
________________ _______________

and Northwest Stationers, do not throw the "rule of reason" out
____________________

the window merely because one establishes that a given practice

among joint venture participants is ancillary to legitimate and

efficient activity -- the injury to competition must still be

weighed against the purported benefits under the rule of reason.

See, e.g., Broadcast Music, 441 U.S. at 24 (holding only that a
___ ____ _______________

particular ancillary restraint did not constitute a per se
_______
-23-


violation of the Sherman Act and remanding for a determination of

the case under a rule of reason analysis); Northwest Stationers,
____________________

472 U.S. at 293-98 (same); see also SCFC ILC, Inc. v. Visa U.S.A.
________ ______________ ___________

Inc., 819 F. Supp. 956, 979-80 (D.Utah 1993) (finding that the
____

existence of a joint venture may save a restraint from per se
______

illegality but not from the normal rule of reason scrutiny).

One basic tenet of the rule of reason is that a given

restriction is not reasonable, that is, its benefits cannot

outweigh its harm to competition, if a reasonable, less

restrictive alternative to the policy exists that would provide

the same benefits as the current restraint. L.A. Coliseum, 726
______________

F.2d at 1396. The record contains evidence of a clearly less

restrictive alternative to the NFL's ownership policy that would

yield the same benefits as the current policy. Sullivan points

to one proposal to amend the current ownership policy by allowing

for the sale of minority, nonvoting shares of team stock to the

public with restrictions on the size of the holdings by any one

individual. Dividend payments, if any, would be within the firm

control of the NFL majority owner. Under such a policy, it would

be reasonable for a jury to conclude that private control of

member clubs is maintained, conflicts of interest are avoided,

and all the other "benefits" of the NFL's joint venture

arrangement are preserved while at the same time teams would have

access to the market for public investment capital through the

sale of ownership interests.

C. Causation of Injury in Fact
C. Causation of Injury in Fact
-24-


The NFL next argues that Sullivan did not present

sufficient evidence to support a finding by the jury that the

NFL's public ownership policy caused injury in fact to Sullivan.

An antitrust plaintiff must prove that he or she suffered damages

from an antitrust violation and that there is a causal connection

between the illegal practice and the injury. Associated General
__________________

Contractors, Inc. v. California State Council of Carpenters, 459
_________________ _______________________________________

U.S. 519, 532-33 & n.26 (1983); Blue Shield of Virginia v.
_________________________

McCready, 457 U.S. 465, 476-78 (1982); Engine Specialties, Inc.
________ ________________________

v. Bombardier Ltd., 605 F.2d 1, 13 (1st Cir. 1979), cert. denied,
_______________ ____ ______

446 U.S. 983 (1980). "Plaintiffs need not prove that the

antitrust violation was the sole cause of their injury, but only

that it was a material cause." Engine Specialties, 605 F.2d at
__________________

14.

Sullivan asserted at trial that the NFL's ownership

policy forced him to sell the Patriots at a depressed price, far

below what the team would have been worth in a market that

included public ownership of the team. "But for" the NFL's

policy, Sullivan claims, he would have been able to offer 49% of

the Patriots to the public for $70 million, pay off his debts,

and retained ownership of a much more valuable and profitable

team.

The NFL contends that Sullivan failed to establish a

causal connection between his "forced" sale of the Patriots and

the NFL's ownership policy because (1) Sullivan never officially

requested a vote on his proposals to amend or waive the policy so
-25-


there is no way of knowing whether the policy would have

prevented a public offering in the first place; and (2) Sullivan

never established that the public stock sale was feasible or

potentially successful and thus an alternative to what ultimately

happened (i.e., even if the NFL did not have a policy against

public ownership, Sullivan would still have had to sell his team

because the Patriots stock sale would not have happened or would

not have raised enough money to pay off Sullivan's debts and

prevent a fire sale of the team). Although the evidence of

causation is not overwhelming, it is nevertheless sufficient to

support the verdict.

Regarding the NFL's first claim that Sullivan never

called for a vote from the owners to change or waive the

ownership policy, Sullivan presented sufficient evidence to show

that the NFL essentially rejected Sullivan's request, even though

no official vote was taken. Under certain circumstances, an

antitrust plaintiff must make a demand on the defendant to allow

the plaintiff to take some action or obtain some benefit, which

the defendant's challenged practice is allegedly preventing the

plaintiff from taking or obtaining, in order to prove that the

practice caused injury in fact to the plaintiff. See Wells Real
___ __________

Estate, Inc. v. Greater Lowell Bd. of Realtors, 850 F.2d 803, 816
____________ ______________________________

(1st Cir.), cert. denied, 488 U.S. 955 (1988); Out Front
____ ______ __________

Productions, Inc. v. Magid, 748 F.2d 166, 170 (3d Cir. 1984).
_________________ _____

Such a requirement only applies,