Last month, the United States Supreme Court unanimously
held that the National Collegiate Athletic Association's
restrictions on education-related compensation for student-athletes
violated Section 1 of the Sherman Antitrust Act (the "Sherman
Act"). National Collegiate Athletic
Association v.
Alston, 2021 WL 2519036 (U.S.
June 21, 2021). The Justices concluded that the district court
properly utilized and applied the more in-depth rule of reason
approach to condemn limits on undergraduate athletic scholarships
and other athletic performance-related compensation. This unanimous
opinion stands in contrast to many antitrust decisions that have
been closely split in recent years.
I. Background
