National Collegiate Athletic Assn. v. Alston, 594 US 69 - Supreme Court 2021

And that is because, as the Supreme Court recently related in its Alston decision, the "NCAA's Division I essentially is the relevant market for elite college football and basketball," and "student-athletes have nowhere else [other than NCAA member schools] to sell their labor."

—holding that the district court did not err in finding that the NCAA violated the Sherman Act by limiting the education-related benefits schools could offer student-athletes

Determining whether a restraint is undue for purposes of the Sherman Act `presumptively'calls for what we have described as a `rule of reason analysis

The Supreme Court affirmed a judgment that evaluated the NCAA's limit on student-athlete compensation under the rule of reason.

Collaboration between the defendants is not required in order to create a new product or market that could not otherwise exist.

The Supreme Court said such quick-look condemnations should be rare, explaining, "we take special care not to deploy these condemnatory tools until we have amassed `considerable experience with the type of restraint at issue'and `can predict with confidence that it would be invalidated in all or almost all instances.'"

Though the Rule of Reason is not a "rote checklist," it also generally requires the parties to produce, and the court to evaluate, evidence regarding a restraint's anticompetitive effects, its procompetitive benefits, and whether there are less restrictive means of accomplishing those benefits.

—college athletes brought suit against the NCAA, claiming its agreement with member schools to limit compensation to student athletes amounted to an unlawful restraint of trade in violation of the Sherman Act.

Moreover, the "NCAA enjoys near complete dominance" of the labor market "for elite college football [.]"

Under this rule, the plaintiff has the initial burden to show the challenged activity's "substantial anticompetitive effect."