Haywood v. National Basketball Association
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''Haywood v. National Basketball Association'', 401 U.S. 1204 (1971), was a
U.S. Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
decision that ruled against the
NBA The National Basketball Association (NBA) is a professional basketball league in North America. The league is composed of 30 teams (29 in the United States and 1 in Canada) and is one of the major professional sports leagues in the United St ...
's requirement that a player could not be drafted by an NBA team until four years after graduating from high school. Justice Douglas, in an
in-chambers opinion {{no footnotes, date=March 2013 An in-chambers opinion is an opinion by a single justice or judge of a multi-member appellate court, rendered on an issue that the court's rules or procedures allow a single member of the court to decide. The judge is ...
, allowed
Spencer Haywood Spencer Haywood (born April 22, 1949) is an American former professional basketball player and Olympic gold medalist. Haywood is a member of the Naismith Memorial Basketball Hall of Fame, being inducted in 2015. High school career In 1964, Hayw ...
to play in the NBA temporarily until the litigation could proceed further. The case was settled out of court, Haywood continued playing, and the NBA modified its four-year rule to allow players to enter the league early in cases of "hardship".


Background

Spencer Haywood Spencer Haywood (born April 22, 1949) is an American former professional basketball player and Olympic gold medalist. Haywood is a member of the Naismith Memorial Basketball Hall of Fame, being inducted in 2015. High school career In 1964, Hayw ...
turned pro after his sophomore season at the
University of Detroit The University of Detroit Mercy is a private Roman Catholic university in Detroit, Michigan. It is sponsored by both the Society of Jesus (Jesuits) and the Sisters of Mercy. The university was founded in 1877 and is the largest Catholic universi ...
, joining the
American Basketball Association The American Basketball Association (ABA) was a major men's professional basketball league from 1967 to 1976. The ABA ceased to exist with the ABA–NBA merger, American Basketball Association–National Basketball Association merger in 1976, ...
’s (ABA)
Denver Rockets Denver () is a consolidated city and county, the capital, and most populous city of the U.S. state of Colorado. Its population was 715,522 at the 2020 census, a 19.22% increase since 2010. It is the 19th-most populous city in the United ...
in 1969. While both the
NBA The National Basketball Association (NBA) is a professional basketball league in North America. The league is composed of 30 teams (29 in the United States and 1 in Canada) and is one of the major professional sports leagues in the United St ...
and the ABA required players to be at least four years removed from their high school graduation, the ABA offered a hardship exemption. With his mother raising 10 children while picking cotton at $2 per day, Haywood met the criteria. Haywood led the ABA in scoring (30.0 per game) and rebounding (19.5 per game) in 1969-70, before jumping to the NBA the following season.
Seattle SuperSonics The Seattle SuperSonics (commonly known as the Seattle Sonics) were an American professional basketball team based in Seattle. The SuperSonics competed in the National Basketball Association (NBA) as a member club of the league's Western Confe ...
owner
Sam Schulman Samuel Schulman (April 10, 1910 – June 12, 2003) was an American businessman from New York who was a founding owner and President of the Seattle SuperSonics of the National Basketball Association and an owner of the San Diego Chargers of the ...
signed Haywood to a six-year, $1.5 million contract, ignoring the four-year rule. As a result, the NBA threatened to disallow the contract and implement various sanctions against the SuperSonics.


Procedural history

Haywood challenged this decision by commencing an antitrust action against the NBA. As part of his claim against the NBA, Haywood argued that the conduct of the NBA was a "group boycott" and a violation of the
Sherman Antitrust Act The Sherman Antitrust Act of 1890 (, ) is a United States antitrust law which prescribes the rule of free competition among those engaged in commerce. It was passed by Congress and is named for Senator John Sherman, its principal author. Th ...
. The central issue that had to be determined was whether the NBA draft policy was a restraint on trade and therefore was illegal in accordance with the Sherman Act. The case was filed in the
United States District Court for the Central District of California The United States District Court for the Central District of California (in case citations, C.D. Cal.; commonly referred to as the CDCA or CACD) is a Federal trial court that serves over 19 million people in Southern and Central California, m ...
, which issued an
injunction An injunction is a legal and equitable remedy in the form of a special court order that compels a party to do or refrain from specific acts. ("The court of appeals ... has exclusive jurisdiction to enjoin, set aside, suspend (in whole or in pa ...
in Haywood's favor, ruling: The NBA appealed to the
Ninth Circuit Court of Appeals The United States Court of Appeals for the Ninth Circuit (in case citations, 9th Cir.) is the U.S. federal court of appeals that has appellate jurisdiction over the U.S. district courts in the following federal judicial districts: * District ...
, which stayed the injunction. Joined by the SuperSonics, Haywood appealed to the Supreme Court, which upheld the District Court, reinstated that court's injunction against the NBA, and remanded the case to the District Court for further proceedings.


Impact

Shortly after the Supreme Court's decision, the league and Haywood reached an out-of-court settlement which allowed him to stay with the Sonics permanently. The decision allowed a significant number of high school graduates and college attendees to make themselves eligible for the NBA draft without waiting until four years after high school.


See also

* List of United States Supreme Court cases, volume 401 *'' Toolson v. New York Yankees'', *'' Silver v. New York Stock Exchange'', *'' Robertson v. National Basketball Association'' 556 F.2d 682 (2nd Cir. 1977) *''
Clarett v. National Football League Maurice Edward Clarett (born October 29, 1983) is a former American football running back who played for the Ohio State Buckeyes football team. He also played professionally for the Omaha Nighthawks of the United Football League (2009–2012), ...
'', 369 F.3d 124 (2d Cir. 2004)


References


Further reading

* *


External links

* {{NBA Drafts United States Supreme Court cases United States Supreme Court cases of the Burger Court United States antitrust case law Sports case law American Basketball Association National Basketball Association draft 1971 in United States case law National Basketball Association controversies