!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1689
See Zach Harper, Commissioner Adam Silver still wants age limit of 20 for draft eligibility, CBS Sports (Nov. 24,
2014, 7:38 PM), http://www.cbssports.com/nba/eye-on-basketball/24838071/commissioner-adam-silver-still-wants-
age-limit-of-20-for-draft-eligibility, archived at https://perma.cc/TX6U-QH6M; Steve Kerr, The Case for the 20-Year-
Old Age Limit in the NBA, Grantland, May 8, 2012, http://grantland.com/features/steve-kerr-problems-age-limit-nba/,
archived at https://perma.cc/BU6U-8T8R.
1690
NBPA leader Michele Roberts: ‘Be happy with one-and-done,’ Sports Illustrated, Feb. 15, 2015,
http://www.si.com/nba/2015/02/15/nba-age-limit-michele-roberts-adam-silver-one-and-done, archived at
http://perma.cc/38K7-QGUN.
1691
See David Aldridge, NBA, NBPA reach tentative seven-year CBA agreement, NBA.com (Dec. 14, 2016, 8:18
PM), http://www.nba.com/article/2016/12/14/nba-and-nbpa-reach-tentative-labor-deal, archived at
https://perma.cc/X5U4-YA73.
1692
2013 NHL CBA, Art. 8, § 8.4(a); NHL By-Law § 12.7.
1693
News reports have indicated that the NHL is considering trying to raise the minimum age to 19. See Allan Muir,
Notebook: Draft age change in store? SPORTS ILLUSTRATED (Mar. 8, 2016), http://www.si.com/nhl/2016/03/07/nhl-draft-
age-change-world-cup-over-35-team-players, archived at https://perma.cc/9L6C-8CL4.
1694
2013 NHL CBA, Art. 8, § 8.4(a).
1695
See Active NHL Players Totals by Nationality - Career Stats, QuantHockey.com,
http://www.quanthockey.com/nhl/nationality-totals/active-nhl-players-career-stats.html (last visited Nov. 30, 2016),
archived at https://perma.cc/8682-9DBY.
1696
Generally only about 20 players are drafted out of high schools each year, or about 10% of drafted players. See
Mike Morreale, NHL teams grab 20 high-schoolers in draft, Nat’l Hockey League (Jun. 23, 2010, 4:31 PM),
http://www.nhl.com/ice/news.htm?id=635956, archived at http://perma.cc/Q4ZR-VHC3; Mike Morreale, NHL teams
draft record 22 high school players, Nat’l Hockey League, Jun. 26, 2010,
http://www.nhl.com/ice/news.htm?id=533004, archived at http://perma.cc/PFZ4-GCW8.
1697
See Katie Strang, Lawsuit seeks to have junior players paid minimum wage, ESPN, Jan. 29, 2015,
http://espn.go.com/blog/nhl/post/_/id/34346/lawsuit-seeks-to-have-junior-players-paid-minimum-wage, archived at
https://perma.cc/5DAL-NPGU.
1698
NCAA Division I Manual Bylaw 12.2.3.2.4 (“Ice hockey teams in the United States and Canada, classified by the
Canadian Hockey Association as major junior teams, are considered professional teams under NCAA legislation.”)
1699
Andrew Podnieks, A Battle Across the Border in Recruiting, Feb. 9, 2011, N.Y. Times
http://www.nytimes.com/2011/02/10/sports/hockey/10hockey.html, archived at http://perma.cc/E9TP-UW5N.; Marc
Bianchi, Guardian of Amateurism or Legal Defiant? The Dichotomous Nature of NCAA Men’s Ice Hockey Regulation,
20 Seton Hall J. Sports & Ent. L. 165 (2010).
1700
Marc Bianchi, Guardian of Amateurism or Legal Defiant? The Dichotomous Nature of NCAA Men’s Ice Hockey
Regulation, 20 Seton Hall J. Sports & Ent. L. 165, 175 (2010).
1701
Andrew Podnieks, A Battle Across the Border in Recruiting, Feb. 9, 2011, N.Y. Times
http://www.nytimes.com/2011/02/10/sports/hockey/10hockey.html, archived at http://perma.cc/E9TP-UW5N.
1702
2013 NHL CBA, Art. 8, § 8.6(c).
1703
2013 NHL CBA, Art. 8, § 8.6(d).
1704
See, e.g., Aaron Portzline, Blue Jackets: Defenseman Mike Reilly to Return to College, Add to Game and Frame,
Columbus Dispatch, July 11, 2014, http://bluejacketsxtra.dispatch.com/content/stories/2014/07/11/still-room-for-
growth.html, archived at http://perma.cc/L3XW-HBT7 (explaining University of Minnesota’s Mike Reilly’s decision to
return to college to put on muscle after adding 36 pounds already in two years of college); Colin Dambrauskas,
Johnny Gaudreau Playing Big – Wants to Join Flames, HockeyBuzz (July 16, 2013, 12:35 p.m.),
http://www.hockeybuzz.com/blog/Colin-Dambrauskas/Johnny-Gaudreau-Playing-Big---Wants-to-Join-
Flames/171/52843, archived at http://perma.cc/9MZN-NSWC (quoting Calgary Flames’ prospect Johnny Gaudreau
as saying, “Hopefully they want me next year at the end of the year and hopefully I can come in and make an impact
for them. If I play well this year and put on the right weight, I think I might be able to do it.”) (emphasis added);
Lightning’s Jonathan Drouin Selected Top Prospect by NHL.com, Tampa Bay Lightning, Sept. 9, 2014,
http://lightning.nhl.com/club/news.htm?id=729872, archived at http://perma.cc/4R9A-X6DG (noting that David
Pastrnak will “need at least one more season in Sweden to get bigger and stronger” and that “[a]t 5-10 and 180
pounds . . . 18-year-old [Kevin Fiala] will need at least one more season with HV 71 in Sweden to get bigger and
1706
Neeld v. Nat’l Hockey League, 594 F.2d 1297, 1300 (9th Cir. 1979) (“the record amply supports the
reasonableness of the by-law”). Under the rule of reason, “the factfinder weighs all of the circumstances of a case in
deciding whether a restrictive practice should be prohibited as imposing an unreasonable restraint on competition,”
including “‘specific information about the relevant business’ and ‘the restraint’s history, nature, and effect.’” Leegin
Creative Leather Products, Inc. v. PSKS, Inc., 551 U.S. 877, 885 (2007) (citations omitted).
1707
Neeld, 594 F.2d at 1300. In addition to the Neeld case, there was a legal challenge to the age eligibility
requirements of professional hockey—albeit a challenge to the World Hockey Association (“WHA”), a 1970s