The business aspects of professional sport dominated the media when a twenty-seven day strike disrupted the 1987 NFL football season, which included the hiring of replacement players, the filing of numerous labor charges by both the NFL Management Council (NFLMC) and the NFL Players' Association (NFLPA) and the dismal end of the strike after many players crossed the picket lines to return to play.' On the day that the NFLPA announced that the strike was over, they also shifted into their final goal line defense: the filing of an antitrust action against the National Football League (NFL) and each individual franchise. On January 29, 1988, a memorandum and opinion was filed concerning the cross-motions for summary judgment in that case.

This article is designed to analyze both the antitrust issues raised in that case and the immediate impact of the district court's memorandum and opinion. To facilitate the analysis, there is a brief history of the NFL and the NFLPA, a section outlining the history of collective bargaining between the two parties including the 1987 strike issues, a discussion of antitrust litigation involving football with emphasis on the current antitrust filing followed by a discussion and analysis of the January 29, 1988, opinion.