There's no 'I' in 'League': Professional sports leagues and the single entity defense

This article examines the split of authority regarding the single entity status of professional sports leagues under Section 1 of the Sherman Act. Specifically, this article argues that outside of labor disputes, sports leagues should be presumed to be single entities. Part I argues that professional sports leagues are single entities in disputes regarding league-wide, nonlabor policy. In particular, the focus of the Supreme Court's jurisprudence on economic reality rather than organizational form necessitates a finding that professional sports leagues are single entities in nonlabor disputes. Part II argues that professional sports leagues are not single entities for purposes of labor disputes; sports leagues, on the whole, do not involve a unity of interest for labor matters. More importantly, existing precedent outside of the professional sports context that balances labor and antitrust law should apply to professional sports. The Note concludes that a general classification scheme should be adopted in which professional sports leagues are presumed to be single entities, with an exception for labor disputes.