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Former Volunteer Baseball Coaches Sue NCAA

Two former Division I volunteer baseball coaches filed a class action lawsuit against the National Collegiate Athletic Association (NCAA), alleging that the NCAA “engaged in an illegal buyer’s-side monopsony by conspiring to fix the compensation of an entire category of college baseball coaches at zero.” Specifically, the lawsuit entitled Smart v. NCAA seeks damages and targets eliminating the volunteer coach position allowed by NCAA Bylaw 11.01.06.

NCAA Bylaws limit the amount of paid baseball coaches to three per team. However, under the NCAA Bylaws, teams may have a fourth “volunteer” coach. The volunteer coach receives zero compensation for their work.

The plaintiffs (Taylor Smart and Michael Hacker) are two former volunteer baseball coaches at the University of Arkansas and the University of California, Davis, respectively. The coaches served as volunteer coaches for multiple seasons.

According to the lawsuit, volunteer coaches perform many of the same duties as their paid counterparts, including working more than 40 hours per work and serving as on-field coaches during games.

As the plaintiffs allege, due to the NCAA reducing the volunteer coach’s salary to zero, the NCAA has restrained the market for baseball coaches and engaged in anti-competitive behavior by price fixing the market. Thus, the NCAA has violated Section 1 of the Sherman Act. In addition, the plaintiffs include claims for violating California’s unfair competition law and unjust enrichment due to the NCAA receiving the benefit of the volunteer coaches’ work yet not paying them.

Possibility Of Success

A similar case against the NCAA reached the United States Court of Appeals for the Tenth Circuit. In Law v. NCAA, another class action lawsuit, the NCAA instituted a rule limiting the salary of Division I entry-level coaches to $16,000. At the District Court, the judge granted summary judgment in favor of the plaintiffs. The Court of Appeals for the Tenth Circuit affirmed the lower court, finding that the NCAA’s rule had an anticompetitive effect due to the rule “lowering the price of coaching services.”

The volunteer baseball coaches in Smart can find further support in NCAA v. Alston, which held that NCAA rules are subject to antitrust scrutiny.

As a class action lawsuit, this matter could take years to resolve. In the end, we will likely see an end to the volunteer coach.

Landis Barber is an attorney at Safran Law Offices in Raleigh, North Carolina. You can connect with him via LinkedIn or via his blog He can be reached on Twitter @Landisbarber.

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