Warriors Sports, Inc. (“Warrior”) set forth an antitrust claim against the NCAA in accordance with Section 1 of the Sherman Antitrust Act. The case involves the NCAA’s regulations relating to lacrosse stick heads that may be used in collegiate play. Warrior alleged that these rules are particularly influential because they not only govern the sticks that may be used in collegiate lacrosse, but they are also adopted by most of the sports’ governing bodies, such as the National Federation of High School Sports.
Before September 2006, the NCAA had used the same rules regarding the allowable dimensions of lacrosse stick heads for thirty (30) years. Manufacturers, including Warrior, were able to submit their sticks to the NCAA to obtain confirmation that their sticks complied with the lacrosse rules, and Warrior specifically noted that it did so in 2000. The pre-September 2006 rule only required that lacrosse heads be at least 6.5” at their widest point and 10” from top to bottom. In September 2006, the NCAA rules committee changed the rules to be effective January 1, 2009.
The NCAA claimed that it was changing the dimensions of the lacrosse stick heads in order to promote free dislodgment of the ball during play. This rule would have rendered the vast majority of all current men’s lacrosse heads illegal. In September 2007 and February 2008, the NCAA changed the rules again. Yet, Warrior was still unhappy with the change of the rules and, therefore, it brought suit citing that the 2008 rule change had been implemented “for improper and anticompetitive reasons under the influence of [Warrior’s] competitors.” NCAA promptly moved for a Motion for Judgment on the Pleadings pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, which was ultimately granted by the U.S. District Court for the Eastern District of Michigan (“District Court”).
Warrior chose to appeal the decision of the District Court to the United States Sixth Circuit Court of Appeals (“6th Circuit”). Although the 6th Circuit chastised the District Court’s analysis, it affirmed the District Court’s opinion by citing that the only result of the 2008 rule change was to increase the number of allowable lacrosse sticks, which would result in increased competition in the market place. The 6th Circuit held that “the adoption of the 2008 rule change was [not] done with a malicious and unlawful purpose,” but the 2008 rule change “equally applies to all manufacturers [and] Warrior may compete in the market on the same footing as other competitors.”
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