Second Circuit rejects NASL bid to revive US Soccer and MLS antitrust case

The US Court of Appeals for the Second Circuit has ruled against the North American Soccer League (NASL), affirming a lower court judgment that rejected the defunct league’s antitrust claims against US Soccer and Major League Soccer.The decision leaves intact the February 3, 2025 jury verdict and the May 6, 2025 post-judgment order that denied NASL a new trial, after the league alleged a conspiracy linked to US Soccer’s Professional League Standards and divisional sanctioning.The appeals court said NASL could not escape the requirement to prove a relevant market under the rule of reason and found that NASL had waived its central argument by previously endorsing the legal framework it later sought to challenge.The ruling stated: “Waiver is the intentional relinquishment or abandonment of a known right.”The panel noted that NASL submitted proposed jury materials that required proof of a relevant market and that NASL counsel told the court the jury must unanimously find a relevant market existed for the claims to succeed.The outcome is commercially significant for the US professional soccer system because it maintains the status quo on how divisional standards and league certification can be structured, and it removes a major litigation overhang around competitive access and market definition.NASL had also challenged earlier trial and pre-trial decisions, including the exclusion of expert testimony and aspects of the evidentiary record, but the appeals court said any potential error would be harmless given the jury’s market finding.The ruling said NASL presented four proposed relevant markets at trial and the jury found that NASL failed to prove any of them, a finding the appeals court described as “dispositive” because market definition is an essential element of each claim.The panel also referenced prior precedent that league sports regulation is a “textbook example” for rule of reason analysis, reflecting the legal view that sports governance restraints can have neutral or procompetitive effects depending on context.The decision provides additional certainty for MLS and US Soccer as US soccer’s commercial cycle accelerates ahead of the FIFA World Cup 2026, a period when rights holders and investors typically place a premium on governance stability and reduced legal risk.Any further move by NASL would require escalation beyond the Second Circuit, but the appeal decision significantly narrows the remaining pathways to reopen the case under US antitrust law.