National Collegiate Athletic Association v. Alston
Case Overview
The Supreme Court unanimously rejected the NCAA's restrictions on education-related compensation for college athletes, holding that the rules limiting certain academic benefits violated federal antitrust law, while the Court also specifically noted, in a concurrence that drew wide attention, that the entire edifice of amateurism rules might not survive antitrust scrutiny, foreshadowing the collapse of the amateur model in college sports.
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The Facts
College athletes challenged NCAA rules that capped or prohibited education-related benefits such as graduate school scholarships, paid post-eligibility internships, and academic awards beyond the cost of attendance. The Ninth Circuit held the restrictions violated the Sherman Act under a rule of reason analysis and prohibited the NCAA from enforcing the challenged restrictions. The Supreme Court granted certiorari to address the scope of antitrust scrutiny applicable to the NCAA's compensation rules.
The Application
The NCAA's restrictions on education-related compensation (including limited graduate scholarships, internships, and academic awards beyond cost of attendance) constituted a horizontal agreement among member schools to suppress the market price for athletic labor, violating Sherman Act § 1's prohibition on restraints of trade among competitors. Under rule of reason analysis, the Court weighed the NCAA's procompetitive justifications (preserving amateurism and competitive balance) against the restrictions' anticompetitive effects and found the latter outweighed the former: by preventing schools from competing through educational compensation, the restraint foreclosed a meaningful avenue for athletic recruitment and talent retention. The breadth of the restrictions (extending even to modest academic achievement awards) demonstrated they were not narrowly tailored to achieve the NCAA's stated objectives, instead functioning as unlawful cartel-like suppression of athlete compensation. The unanimous decision applied standard antitrust doctrine to NCAA compensation rules without extending special deference, confirming that horizontal compensation agreements in college athletics must satisfy competitive scrutiny like other industries.
The Conclusion
Decided June 21, 2021. The Court affirmed 9-0 that the NCAA's restrictions on education-related compensation violated the Sherman Act. Justice Gorsuch's concurrence, joined by all, emphasized there was nothing 'new' about applying antitrust law to the NCAA. Justice Kavanaugh wrote separately to observe that the NCAA's broader amateurism model -- including limits on pay for athletic performance -- likely also violated antitrust law. The ruling launched the NIL era in college sports.
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