American Needle Vs National Football League Case Study

The National Football League traces its history back to the 1920’s, when the American Professional Football Association was initially founded. The original league consisted of only ten teams, centralized in a mere four states. This small, regional league grew into the thirty-two team league known today as the National Football League, which holds a national, even global presence. Recently, in 2010, the Supreme Court was asked to decide whether the National Football League was a single entity or a group of thirty-two independent organizations. In this case, American Needle v. National Football League, the Supreme Court determined that each team is a substantial, independently owned, and independently managed organization, with independent objectives

For example many wide-reaching decisions are made at the annual owner meeting. At these meetings, the owners of each NFL team hold conferences to discuss the state of the NFL. The NFL owners discuss substantive rule changes that have widespread applicability to the league, and thus, all thirty-two teams. For example, last year a decision was made to move the ball on the point after touchdown attempt, or PAT, to the fifteen yard line, instead of the two yard line. This year the owners passed a resolution eliminating the “chop block” from the game. The rule changes decided at these meetings drastically change the game and affect every team in the league. The owners act similarly to board members of a single entity, with the commissioner acting as the chairman. This type of centralized decision making is a strong marker that the NFL is a single entity, and thus should be legally recognized as

National Basketball Association. In Levin, the court held that the NBA was a joint partnership, and therefore, the NBA could reject applicants to join the league. In this decision the court regards the NBA as a single entity; however, the court in American Needle held the NFL was not a single entity. The American Needle decision does not make comport with the Levin holding. The NBA is set up in substantially the same way as the NFL; there are thirty member teams of the association, which are held together by the NBA and led by a commissioner. The NBA, in resemblance of the NFL, also engages in revenue sharing and annual owner meetings. As a result of the correlating structure of the NFL to the NBA, the NFL should be viewed as a single entity in order reconcile the holdings of the court in Levin and American