In Brown v. Pro Football, Inc., 518 U.S. 231 (1996), the Court gave two primary reasons for shielding owners from antitrust liability: (1) a concern that such liability would stifle behavior integral to the bargaining process, and (2) a desire to defer to the congressionally sanctioned balance of power between labor unions, owners, and the National Labor Relations Board. See id. at 236-37, 241-42. With regard to the first reason, the Court recognized that the nonstatutory labor exemption was necessary to avoid placing the owners in an untenable position, observing that permitting antitrust liability in such situations would introduce instability and uncertainty into the collective-bargaining process, for antitrust law often forbids or discourages the kinds of joint discussions and behavior that the collective-bargaining process invites or requires. Id. at 242.