In Baseball on Trial, legal scholar Nathaniel Grow defies conventional wisdom to explain why the unanimous Supreme Court opinion authored by Justice Oliver Wendell Holmes, which gave rise to Major League Baseball's exemption from antitrust law, was correct given the circumstances of the time. Currently a billion dollar enterprise, professional baseball teams crisscross the country while the games are broadcast via radio, television, and internet coast to coast. The sheer scope of this activity would seem to embody the phrase "interstate commerce.
Facts[ edit ] After the Federal League folded inmost of the Federal League owners had been bought out by owners in the other major Leagues, or had been compensated in other ways for example, the owner of the St. Louis Federal League team had been permitted to buy the St.
The owner of the Baltimore Terrapins had not, and sued the National Leaguethe American League and other defendants, including several Federal League officials for conspiring to monopolize baseball by destroying the Federal League.
Judgment[ edit ] Court of Appeals[ edit ] The Court of Appeals reversed the trial verdict, and held that baseball was not subject to the Sherman Act. The case was appealed to the Supreme Court. This is a suit for threefold damages brought by the plaintiff in error under the Anti-Trust Acts of July 2,c.
The defendants are the National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs, unincorporated associations, composed respectively of groups of eight incorporated baseball clubs, joined as defendants; the presidents of the two Leagues and a third person, constituting what is known as the National Commission, having considerable powers in carrying out an agreement between the two Leagues, and three other persons having powers in the Federal League of Professional Base Ball Clubs, the relation of which to this case will be explained.
It is alleged that these defendants conspired to monopolize the baseball business, the means adopted being set forth with a detail which, in the view that we take, it is unnecessary to repeat. The plaintiff is a baseball club incorporated in Maryland, and, with seven other corporations, was a member of the Federal League of Professional Base Ball Players, a corporation under the laws of Indiana, that attempted to compete with the combined defendants.
It alleges that the defendants destroyed the Federal League by buying up some of the constituent clubs and in one way or another inducing all those clubs except the plaintiff to leave their League, and that the three persons connected with the Federal League and named as defendants, one of them being the President of the League, took part in the conspiracy.
Great damage to the plaintiff is alleged. The appellee, the plaintiff, elected to stand on the record in order to bring the case to this Court at once, and thereupon judgment was ordered for the defendants. National League of Professional Baseball Clubs v. Federal Baseball Club of Baltimore, 50 App.
It is not argued that the plaintiff waived any rights by its course. CayserU. A summary statement of the nature of the business involved will be enough to present the point. The clubs composing the Leagues are in different cities and for the most part in different states. The end of the elaborate organizations and sub-organizations that are described in the pleadings and evidence is that these clubs shall play against one another in public exhibitions for money, one or the other club crossing a state line in order to make the meeting possible.
Of course, the scheme requires constantly repeated traveling on the part of the clubs, which is provided for, controlled, and disciplined by the organizations, and this, it is said, means commerce among the states. But we are of opinion that the Court of Appeals was right.
The business is giving exhibitions of baseball, which are purely state affairs. It is true that, in order to attain for these exhibitions the great popularity that they have achieved, competitions must be arranged between clubs from different cities and states.
But the fact that, in order to give the exhibitions, the Leagues must induce free persons to cross state lines and must arrange and pay for their doing so is not enough to change the character of the business.
According to the distinction insisted upon in Hooper v. CaliforniaU. That to which it is incident, the exhibition, although made for money, would not be called trade of commerce in the commonly accepted use of those words. As it is put by defendant, personal effort not related to production is not a subject of commerce.
That which in its consummation is not commerce does not become commerce among the states because the transportation that we have mentioned takes place.
To repeat the illustrations given by the court below, a firm of lawyers sending out a member to argue a case, or the Chautauqua lecture bureau sending out lecturers, does not engage in such commerce because the lawyer or lecturer goes to another state.
The case was reaffirmed in Toolson v. New York Yankees, Inc. Kuhnthe Court partially reversed, and found Major League Baseball to be engaged in interstate commerce.Federal Baseball Club v.
National League, U.S. (), is a case in which the U.S. Supreme Court ruled that the Sherman Antitrust Act did not apply to Major League Baseball. A. Major League Baseball is the only professional sport league exempt from antitrust laws.
B. All professional sports leagues' national broadcasting agreements are exempt from antitrust laws.
The controversial antitrust exemption dates to the early years of organized ball. In January , the American and National Leagues united to form Major League Baseball.
The case is generally known as having held that baseball has an “antitrust exemption.” One ad promised that the Buffed organization would be “one of the greatest financial successes in the history of baseball. Major League Baseball Attendance for BASEBALL'S ANTITRUST EXEMPTION sociation, and the National Hockey League which operate as self-contained entities, Major League Baseball is merely one part of an elab-.
On January 5, , the Federal League sued Major League Baseball under federal antitrust law for interfering with their attempts to hire players that were between contracts (meaning not bound by the Reserve Clause) from the American and National League.