Federal Baseball Club v. National League
Encyclopedia
Federal Baseball Club v. National League, , is a case in which the U.S. Supreme Court
ruled that the Sherman Antitrust Act
did not apply to Major League Baseball
.
folded in 1915, most 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. Louis Browns). The owner of the Baltimore Federal League club (the Baltimore Terrapins
) had not, and sued the National League
, the American League
and other defendants, including several Federal League officials for conspiring to monopolize baseball by destroying the Federal League. At trial, the defendants were found jointly liable, and damages of $80,000 assessed, which was tripled to $240,000 ($ as of ), under the provisions of the Clayton Antitrust Act
.
On appeal, the Court of Appeals reversed the trial verdict, and held that baseball was not subject to the Sherman Act, and the case was duly appealed to the Supreme Court. In a unanimous decision written by Justice Oliver Wendell Holmes, Jr.
, the Court affirmed the Court of Appeals, holding that "the business is giving exhibitions of base ball[sic], which are purely state affairs"; that is, that baseball was not interstate commerce
for the purposes of the Sherman Act.
The decision was reaffirmed in Toolson v. New York Yankees
, , and Flood v. Kuhn
, .
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
ruled that the Sherman Antitrust Act
Sherman Antitrust Act
The Sherman Antitrust Act requires the United States federal government to investigate and pursue trusts, companies, and organizations suspected of violating the Act. It was the first Federal statute to limit cartels and monopolies, and today still forms the basis for most antitrust litigation by...
did not apply to Major League Baseball
Major League Baseball
Major League Baseball is the highest level of professional baseball in the United States and Canada, consisting of teams that play in the National League and the American League...
.
Background
After the Federal LeagueFederal League
The Federal League of Base Ball Clubs, known simply as the Federal League, was an American professional baseball league that operated as a "third major league", in competition with the established National and American Leagues, from to...
folded in 1915, most 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
St. Louis, Missouri
St. Louis is an independent city on the eastern border of Missouri, United States. With a population of 319,294, it was the 58th-largest U.S. city at the 2010 U.S. Census. The Greater St...
Federal League team had been permitted to buy the St. Louis Browns). The owner of the Baltimore Federal League club (the Baltimore Terrapins
Baltimore Terrapins
The Baltimore Terrapins were one of the most successful teams in the short-lived Federal League of professional baseball from to , but their brief existence led to litigation that led to an important legal precedent in baseball...
) had not, and sued the National League
National League
The National League of Professional Baseball Clubs, known simply as the National League , is the older of two leagues constituting Major League Baseball, and the world's oldest extant professional team sports league. Founded on February 2, 1876, to replace the National Association of Professional...
, the American League
American League
The American League of Professional Baseball Clubs, or simply the American League , is one of two leagues that make up Major League Baseball in the United States and Canada. It developed from the Western League, a minor league based in the Great Lakes states, which eventually aspired to major...
and other defendants, including several Federal League officials for conspiring to monopolize baseball by destroying the Federal League. At trial, the defendants were found jointly liable, and damages of $80,000 assessed, which was tripled to $240,000 ($ as of ), under the provisions of the Clayton Antitrust Act
Clayton Antitrust Act
The Clayton Antitrust Act of 1914 , was enacted in the United States to add further substance to the U.S. antitrust law regime by seeking to prevent anticompetitive practices in their incipiency. That regime started with the Sherman Antitrust Act of 1890, the first Federal law outlawing practices...
.
On appeal, the Court of Appeals reversed the trial verdict, and held that baseball was not subject to the Sherman Act, and the case was duly appealed to the Supreme Court. In a unanimous decision written by Justice Oliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr. was an American jurist who served as an Associate Justice of the Supreme Court of the United States from 1902 to 1932...
, the Court affirmed the Court of Appeals, holding that "the business is giving exhibitions of base ball[sic], which are purely state affairs"; that is, that baseball was not interstate commerce
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
for the purposes of the Sherman Act.
The decision was reaffirmed in Toolson v. New York Yankees
Toolson v. New York Yankees
Toolson v. New York Yankees is a 1953 U.S. Supreme Court decision that upheld, 7–2, the antitrust exemption first granted to Major League Baseball three decades earlier in Federal Baseball Club v. National League...
, , and Flood v. Kuhn
Flood v. Kuhn
Flood v. Kuhn was a 1972 United States Supreme Court decision upholding, by a 5–3 margin, the antitrust exemption first granted to Major League Baseball in Federal Baseball Club v. National League. It arose from a challenge by St. Louis Cardinals' outfielder Curt Flood when he refused to be...
, .