Toolson v. New York Yankees
| Toolson v. New York Yankees | |
|---|---|
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| Argued October 13, 1953 Decided November 9, 1953 |
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| Full case name | George Earl Toolson v. New York Yankees, Inc., et al. |
| Citations | 346 U.S. 356 (more)
74 S. Ct. 78; 98 L. Ed. 64; 1953 U.S. LEXIS 2680; 1953 Trade Cas. (CCH) P67,602
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| Prior history | Cert. to the United States Court of Appeals for the Ninth Circuit |
| Holding | |
| Congressional intent to maintain antitrust exemption for professional baseball created by prior Court presumed as a result of congressional inaction since that decision; proper remedy is thus legislative action | |
| Court membership | |
| Case opinions | |
| Per curiam. | |
| Dissent | Burton, joined by Reed |
| Laws applied | |
| Sherman Antitrust Act | |
Toolson v. New York Yankees, 346 U.S. 356 (1953), is a United States Supreme Court case in which the Court upheld, 7–2, the antitrust exemption first granted to Major League Baseball (MLB) three decades earlier in Federal Baseball Club v. National League. It was also the first challenge to the reserve clause which prevented free agency, and one of the first cases heard and decided by the Warren Court.
Since it presumed that Congress's failure to act in the years since Federal Baseball Club was an implicit expression of intent to keep baseball exempt from the Sherman Antitrust Act, it has been read as having done more to create that exemption than the older case. Two justices (Stanley Forman Reed and Harold Hitz Burton) dissented from the short, unsigned per curiam majority opinion, arguing MLB and its revenue sources had changed enough since 1922 that the logic of that case no longer applied. In 1972, a third justice (William O. Douglas) would express his regret at having joined the majority when Toolson was again upheld in the similar Flood v. Kuhn.
George Earl Toolson was a pitcher with the Newark Bears in 1949, a farm team for the New York Yankees in the AAA-class International League. He believed he was good enough to play in the major leagues, if not for the Yankees then for another team. But due to the reserve clause in his and every other player's contract, under which teams reserved rights to a player for a year after the contract expired, he was effectively bound to the talent-rich Yankees and could not negotiate a new contract with another team.
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