NCAA and the Rule of Reason: Analyzing Improved Education Quality as a Procompetitive Justification

This Note analyzes the recent United States District Court for the Northern District of California decision in the O'Bannon v. NCAA case. The Note focuses narrowly on the court's decision to hold that improved education quality is a procompetitive benefit that justifies NCAA rules that restrict student-athlete compensation. The analysis lays out the relevant antitrust framework and compares the court's decision to Supreme Court precedent in National Society of Professional Engineers v. United States, FTC v. Indiana Federation of Dentists, and FTC v. Superior Court Trial Lawyers Association. The Note concludes that improved product quality in this situation does not justify the restraints in question. If compensating student-athletes really does decrease education quality, each university and prospective student-athlete can consider that before offering or accepting financial aid beyond the traditional athletic scholarship.