Haywood v. National Basketball Association

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 $ per day in ), Haywood met the criteria.

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.

Procedural history

Haywood challenged this decision by commencing an antitrust action against the NBA.

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:

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.

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. The ABA would also host a similar type of draft during this period of time called the "special circumstances draft" in 1971 and 1973 following the results of this case. The NBA would also allow for the "hardship draft" to exist under that nature for a few years before abolishing that effort by the 1976 NBA draft in relation to the NBA-ABA merger in exchange for allowing college underclassmen (and later, high school players during a certain period of time) to join the rest of the draft eligible players so long as they declare their intent to enter the draft and stay in it during the period of time they're allotted to before potentially being selected by a team of interest.

References

References

1. McGregor, Gilbert. (April 22, 2021). "Spencer Haywood: The story of a groundbreaking NBA legend, through his words". Sporting News.
2. Kosmider, Nick. (September 26, 2019). "Fifty years later, it's time for Denver to give Spencer Haywood his due". The Athletic.
3. 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. Violations of the Sherman Antitrust Act had also previously played a factor with the NBA due to the league allowing for early talks of an [[ABA-NBA merger. NBA-ABA merger]] to follow suit in exchange for the ABA to drop a potential lawsuit on their end.Pluto, Terry, ''Loose Balls: The Short, Wild Life of the American Basketball Association'' (Simon & Schuster, 1990), {{ISBN. 978-1-4165-4061-8, p. 426
4. Friedman, David. (2005-04-18). "Excerpt, "Chocolate Thunder and Short Shorts: The NBA in the 1970s"". Basketball in America: From the Playgrounds to Jordan's Game and Beyond.
5. Rhoden, William C.. (June 29, 2016). "Early Entry? One and Done? Thank Spencer Haywood for the Privilege". The New York Times.