Haywood v. National Basketball Association
Haywood v. National Basketball Association, 401 U.S. 1204 (1971), was a U.S. Supreme Court decision that ruled against the NBA'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, allowed Spencer Haywood 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".
| Haywood v. N.B.A. | |
|---|---|
 | |
| Decided March 1, 1971 | |
| Full case name | In re Spencer Haywood v. National Basketball Association |
| Citations | 401 U.S. 1204 (more) 91 S. Ct. 672; 28 L. Ed. 2d 206 |
| Holding | |
| Haywood was granted an injunction pendente lite which allowed him to play for Seattle and forbade the NBA to impose sanctions on the Seattle team. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Douglas |
| All other justices took no part in the consideration or decision of the case. | |
| Laws applied | |
| Sherman Antitrust Act | |
Background
Spencer Haywood turned pro after his sophomore season at the University of Detroit, joining the American Basketball Association’s (ABA) Denver Rockets in 1969. While both the NBA 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 (equivalent to about $16 per day in 2022), Haywood met the criteria.[1][2]
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 owner Sam Schulman 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.[3]
Procedural history
Haywood challenged this decision by commencing an antitrust action against the NBA.[4] 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 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, which issued an injunction in Haywood's favor, ruling:
If Haywood is unable to continue to play professional basketball for Seattle, he will suffer irreparable injury in that a substantial part of his playing career will have been dissipated, his physical condition, skills, and coordination will deteriorate from lack of high-level competition, his public acceptance as a super star will diminish to the detriment of his career, his self-esteem, and his pride will have been injured and a great injustice will be perpetrated on him.
The NBA appealed to the Ninth Circuit Court of Appeals, 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.[3]
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.[4]
See also
- List of United States Supreme Court cases, volume 401
- Toolson v. New York Yankees, 346 U.S. 356 (1953)
- Silver v. New York Stock Exchange, 373 U.S. 341 (1963)
- Robertson v. National Basketball Association 556 F.2d 682 (2nd Cir. 1977)
- Clarett v. National Football League, 369 F.3d 124 (2d Cir. 2004)
References
- McGregor, Gilbert (April 22, 2021). "Spencer Haywood: The story of a groundbreaking NBA legend, through his words". Sporting News. Retrieved May 29, 2022.
- Kosmider, Nick (September 26, 2019). "Fifty years later, it's time for Denver to give Spencer Haywood his due". The Athletic. Retrieved May 29, 2022.
But they had a hardship exception, and Haywood, whose mother raised 10 children while making $2 per day picking cotton in Mississippi, met the criteria.
- Friedman, David (April 18, 2005). "Excerpt, "Chocolate Thunder and Short Shorts: The NBA in the 1970s"". Basketball in America: From the Playgrounds to Jordan's Game and Beyond. Archived from the original on September 8, 2008. Retrieved November 13, 2008.
- Rhoden, William C. (June 29, 2016). "Early Entry? One and Done? Thank Spencer Haywood for the Privilege". The New York Times. Retrieved May 29, 2022.
Further reading
- Allison, John R. (1973). "Professional Sports and the Antitrust Laws: Status of the Reserve System". Baylor Law Review. XXV (1).
- Spears, Marc J.; Washburn, Gary (2020). The Spencer Haywood Rule: Battles, Basketball, and the Making of an American Iconoclast. Chicago: Triumph Books. ISBN 978-1-64125-387-1.
- Wise, Aaron N.; Meyer, Bruce S. (1997). International Sports Law and Business. New York: Kluwer Law International. pp. 47–48. ISBN 90-411-0977-3.
External links
- Text of Haywood v. National Basketball Association, 401 U.S. 1204 (1971) is available from: CourtListener Findlaw Justia Library of Congress