''Federal Baseball Club v. National League'', 259 U.S. 200 (1922), is a case in which the
U.S. Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
ruled that the
Sherman Antitrust Act
The Sherman Antitrust Act of 1890 (, ) is a United States antitrust law which prescribes the rule of free competition among those engaged in commerce. It was passed by Congress and is named for Senator John Sherman, its principal author.
Th ...
did not apply to
Major League Baseball
Major League Baseball (MLB) is a professional baseball organization and the oldest major professional sports league in the world. MLB is composed of 30 total teams, divided equally between the National League (NL) and the American League (AL), ...
.
Background
After the
Federal League
The Federal League of Base Ball Clubs, known simply as the Federal League, was an American professional baseball league that played its first season as a minor league in 1913 and operated as a "third major league", in competition with the e ...
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 Terriers
The St. Louis Terriers were a baseball club that played in the short-lived Federal League in and . They played their home games at Handlan's Park. The team was owned by ice magnate Phil Ball, who later was owner of the St. Louis Browns.
In thei ...
of the Federal League had been permitted to buy the
St. Louis Browns
The St. Louis Browns were a Major League Baseball team that originated in Milwaukee, Wisconsin, as the Milwaukee Brewers. A charter member of the American League (AL), the Brewers moved to St. Louis, Missouri, after the 1901 season, where they ...
of the
American League
The American League of Professional Baseball Clubs, known simply as the American League (AL), is one of two leagues that make up Major League Baseball (MLB) in the United States and Canada. It developed from the Western League, a minor league ...
. The owner of the
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. The team played i ...
had not been compensated, and sued the
National League
The National League of Professional Baseball Clubs, known simply as the National League (NL), is the older of two leagues constituting Major League Baseball (MLB) in the United States and Canada, and the world's oldest extant professional team s ...
, the
American League
The American League of Professional Baseball Clubs, known simply as the American League (AL), is one of two leagues that make up Major League Baseball (MLB) in the United States and Canada. It developed from the Western League, a minor league ...
and other defendants, including several Federal League officials for conspiring to monopolize baseball by destroying the Federal League. In 1919, the defendants were found jointly liable, and damages of $80,000 assessed, which was tripled to $240,000 under the provisions of the
Clayton Antitrust Act
The Clayton Antitrust Act of 1914 (, codified at , ), is a part of United States antitrust law with the goal of adding further substance to the U.S. antitrust law regime; the Clayton Act seeks to prevent anticompetitive practices in their incipie ...
.
Judgment
Court of Appeals
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.
Supreme Court
In a unanimous decision written by Justice
Oliver Wendell Holmes, the Court affirmed the Court of Appeals, holding that "the business is giving exhibitions of base ball, which are purely state affairs"; that is, that baseball was not
interstate commerce
The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and among ...
for the purposes of the Sherman Act. Justice Holmes' decision was as follows:
Significance
This case is the main reason why MLB has not faced any competitor leagues since 1922, and MLB, to date, remains the only American sports league with such an antitrust exemption.
The case was reaffirmed in ''
Toolson v. New York Yankees, Inc. ''
In ''
Flood v. Kuhn
''Flood v. Kuhn'', 407 U.S. 258 (1972), was a decision by the Supreme Court of the United States that preserved the reserve clause in Major League Baseball (MLB) players' contracts. By a 5–3 margin, the Court reaffirmed the antitrust exempti ...
'', the Court partially reversed, and found Major League Baseball to be engaged in interstate commerce. However, the justices refused to overturn baseball's original antitrust exemption from ''Federal Baseball'', deeming it necessary to preserve precedent: in addition to ''Toolson'', the case had already been heavily cited in ''Shubert'', ''
International Boxing'', and ''
Radovich Radovich is a surname. Notable people with the surname include:
*Bill Radovich (1915–2002), American football player
* Dragan Radovich (born 1956), American soccer player
*Drew Radovich (born 1985), American football player
* Frank Radovich (born ...
''.
In 2016's ''
Direct Marketing Association v. Brohl
''Direct Marketing Association v. Brohl'', 575 U.S. 1 (2015), was a United States Supreme Court case in which the Court held that a lawsuit by the Direct Marketing Association trade group about a Colorado law regarding reporting the state's tax re ...
'', the 10th Circuit's
Neil Gorsuch
Neil McGill Gorsuch ( ; born August 29, 1967) is an American lawyer and judge who serves as an associate justice of the Supreme Court of the United States. He was nominated by President Donald Trump on January 31, 2017, and has served since ...
cited ''Federal Baseball'' and ''Toolson'' in his concurrence as one of the "precedential islands
along with ''Bellas Hess'', that">Bellas_Hess.html" ;"title=" along with ''Bellas Hess"> along with ''Bellas Hess'', thatmanage[s] to survive indefinitely even when surrounded by a sea of contrary law…. [that] would never expand but would, if anything,
wash away with the tides of time".
[ N.B: Two years later, Associate Justice Gorsuch would wash away the ''Bellas Hess'' "precedential island" in the ''Wayfair'' decision.]
See also
*
1922 in baseball
Champions
*World Series: New York Giants over New York Yankees (4-0-1)
Statistical leaders
Major league baseball final standings
American League final standings
National League final standings
Negro leagues final standings
Negro Nationa ...
*
Baseball law
Baseball law refers to the various civil statutes, local ordinances, and court decisions pertaining to the game of baseball and its institutions, as distinguished from the Rules of Baseball, which are a private codification of rules governing the ...
*
List of United States Supreme Court cases, volume 259
This is a list of cases reported in volume 259 of ''United States Reports'', decided by the Supreme Court of the United States in 1922.
Justices of the Supreme Court at the time of volume 259 U.S.
The Supreme Court is established by ...
References
External links
*
{{Federal League
History of Major League Baseball
United States Supreme Court cases
United States Supreme Court cases of the Taft Court
United States antitrust case law
Baseball law
Federal League
1922 in United States case law
Baltimore Terrapins
Major League Baseball litigation