18th Annual Workplace Class Action Report - 2022 Edition

Annual Workplace Class Action Litigation Report: 2022 Edition 307 when determining whether a restraint was undue for purposes of the Sherman Act, which required a fact-specific assessment of market power and market structure to assess a challenged restraint’s actual effect on competition. Second, the Supreme Court ruled that the District Court did not err in finding that the NCAA violated the Sherman Act by limiting the education-related benefits that its member schools could offer student-athletes, such as rules limiting scholarships for graduate or vocational school, payments for academic tutoring, or paid post-eligibility internships. The Supreme Court also held that the District Court properly applied a rule of reason analysis and nowhere required the NCAA to show that its compensation rules constituted the least restrictive means of preserving consumer demand, and it was only after finding that the restraints were stricter than necessary to achieve demonstrated procompetitive benefits that the District Court found a violation of the Sherman Act. Id.