[Editors’ note: This is the second in our series, What Is the Most Important U.S. Supreme Court Case in Your Area of the Law? The first installment is here. In this post, Prof. Waxman focuses on an important Supreme Court case from the last term.]

Last spring in American Needle, Inc. v. National Football League, 130 S. Ct. 2201 (2010), the United States Supreme Court reversed two lower court decisions and held that under Copperweld Corp. v. Independence Tube Corp., 467 U.S. 752 (1984), National Football League Properties (NFLP) was not a single entity but rather a collection of different entities with “independent centers of (business and economic) decision-making.” In Copperweld, the Court held that parties within a corporate entity or closely held affiliate (e.g. a wholly owned or controlled subsidiary) are to be treated as a single entity under the antitrust laws (despite the possible treatment as separate entities under corporation law) and therefore not subject to Section 1 of the Sherman Antitrust Act. By its decision in Copperweld, the Court in effect invited parties that might otherwise be treated as more than one entity under the Sherman Act to assert that they fall under the “single entity” category. Historically, despite efforts by many sports leagues to try various business arrangements to fit under the single entity category, courts have denied regularly these assertions based on the understanding that the arrangements were really vehicles controlled by multiple parties with different corporate and economic interests.