Federal Baseball Club v. National League
| Federal Baseball Club v. National League | |
|---|---|
|
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| Argued April 19, 1922 Decided May 29, 1922 |
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| Full case name | Federal Base Ball Club of Baltimore, Inc. v. National League of Professional Base Ball Clubs, et al. |
| Citations | 259 U.S. 200 (more) |
| Holding | |
| Major League Baseball is not considered interstate commerce under the Sherman Antitrust Act. | |
| Court membership | |
| Case opinions | |
| Majority | Holmes, joined by unanimous |
| Laws applied | |
| Sherman Antitrust Act | |
Federal Baseball Club v. National League, 259 U.S. 200 (1922), is a case in which the U.S. Supreme Court ruled that the Sherman Antitrust Act did not apply to Major League Baseball.
After the Federal League 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 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 ($19.6 million as of 2015), 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, which are purely state affairs"; that is, that baseball was not interstate commerce for the purposes of the Sherman Act. Justice Holmes' decision was as follows:
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 plaintiff obtained a verdict for $80,000 in the Supreme Court, and a judgment for treble the amount was entered, but the Court of Appeals, after an elaborate discussion, held that the defendants were not within the Sherman Act. 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.D.C. 165, 269 F. 681, 68. It is not argued that the plaintiff waived any rights by its course. Thomsen v. Cayser, 243 U. S. 66.
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