Tom Brady, et al. v. National Football League, et al., No. 11-1898 (8th Cir. 2011)
Annotate this CaseThis appeal stemmed from an action filed by nine professional football players and one prospective football player (Players) against the National Football League and its 32 separately-owned clubs (NFL or League). On March 11, 2011, a collective bargaining agreement between the League and a union representing professional football players expired and the League made known that if a new agreement was not reached before the expiration date, then it would implement a lockout of players, during which athletes would not be paid or permitted to use club facilities. The Players, aware of the League's strategy, opted to terminate the union's status as their collective bargaining agent as of 4:00 p.m. on March 11, just before the agreement expired. Later that day, the Players filed an action in the district court alleging that the lockout planned by the League would constitute a group boycott and price-fixing agreement that would violate Section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, and alleging other violations of the antitrust laws and state common law. The League proceeded with its planned lockout on March 12, 2011 and the Players moved for a preliminary injunction in the district court, urging the court to enjoin the lockout as an unlawful group boycott that was causing irreparable harm to the Players. The district court granted a preliminary injunction and the League appealed. The court held that the injunction did not conform to provisions of the Norris-LaGuardia Act (Act), 29 U.S.C. 101 et seq., where Section 4(a) of the Act deprived a federal court of power to issue an injunction prohibiting a party to a labor dispute from implementing a lockout of its employees. Therefore, the court vacated the district court's order and declined to reach the other points raised by the League on appeal.
Court Description: Civil case - Labor Law. Section 4(a) of the Norris-LaGuardia Act deprives a federal court of power to issue an injunction prohibiting a party to a labor dispute from implementing a lockout of its employees, and the district court's preliminary injunction against the National Football League's lockout of employees is vacated. Judge Bye, dissenting.
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