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American Football League v. National Football League, 323 F.2d 124 (1963)

Section II of the Sherman Act prohibits persons or entities from monopolizing, attempting to monopolize, or conspiring to monopolize. In determining whether a defendant has violated Section II of the Sherman Act, a court must first define the relevant market and then decide whether the defendant possessed monopoly power in that market. In American Football League versus National Football League, the United States Court of Appeals for the Fourth Circuit assessed how to define the relevant market for franchise expansion of professional football.

The National Football League, or NFL, is an unincorporated association of professional football teams in the United States. In 1959, the American Football League, or AFL, was formed and planned to have teams in eight cities, including Dallas and Minneapolis. At the time, the NFL wanted to expand and granted applications for new franchises in the two cities.

Subsequently, the AFL brought a private antitrust action against the NFL in federal district court under Section II of the Sherman Act. Specifically, the AFL argued that the NFL granted the franchise applications for Dallas and Minneapolis to frustrate the AFL’s plan of starting teams in those cities in an attempt, or as part of a conspiracy, to monopolize the market.

The district court dismissed the case, concluding that the relevant market was nationwide, and the NFL didn’t have the power to monopolize the relevant market. The AFL appealed to the Fourth Circuit, arguing that the market should’ve been defined as the cities where the NFL operated or seriously considered expanding.

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