On May 24, 2004, in Clarett v. National Football League, the Second Circuit reversed the District Court's holding that the NFL eligibility rule which prohibited any player less than three football seasons removed from high school from participating in the draft violated the antitrust laws.

The Second Circuit noted that the rule was part of a collective bargaining agreement. The Courts have established a non-statutory exception to the antitrust laws, whose purpose is to allow meaningful collective bargaining to take place by protecting some restraints on competition imposed through the bargaining process from antitrust scrutiny.

The Court held that it would not give football players rights under the antitrust laws that were not enjoyed by transport workers, coal miners or meat packers. As no important antitrust policies would be vindicated by upholding the antitrust claim, the Court applied the exception and remanded the case to the District Court, where judgment will be entered in favor of the NFL.

Maurice Clarett will have to wait until next year to play in the NFL.

The decision can be found here.