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Keywords

contractlawsuitdefendantprecedentappealtrustantitrust
contractdefendanttrustantitrust

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Flood v. Kuhn, 407 U.S. 258, 92 S.Ct. 2099, 32 L.Ed.2d 728, 1972 Trade Cases P 74,041

Facts

Curtis Charles Flood, a professional baseball player, was traded to the Philadelphia Phillies without his consent or prior knowledge. After the trade, he requested to be made a free agent, which was denied by the Commissioner of Baseball. Flood subsequently filed an antitrust lawsuit against the Commissioner, the presidents of the major leagues, and the major league clubs, challenging the reserve clause that restricted players' ability to negotiate contracts freely. The District Court dismissed his complaint, and the Court of Appeals affirmed the decision.

Issue

Whether the reserve clause in professional baseball, which restricts players from negotiating contracts freely, is exempt from federal antitrust laws.

Whether the reserve clause in professional baseball, which restricts players from negotiating contracts freely, is exempt from federal antitrust laws.

Rule

The longstanding exemption of professional baseball from federal antitrust laws is based on the precedent set by Federal Baseball Club v. National League, 259 U.S. 200 (1922), and Toolson v. New York Yankees, Inc., 346 U.S. 356 (1953). The Supreme Court has held that this exemption is an established aberration that Congress has acquiesced to, and any changes to this status must come from legislative action rather than judicial intervention.

The longstanding exemption of professional baseball from the antitrust laws, Federal Baseball Club v. National League, 259 U.S. 200, 42 S.Ct. 465, 66 L.Ed. 898 (1922); Toolson v. New York Yankees, Inc., 346 U.S. 356, 74 S.Ct. 78, 98 L.Ed. 64 (1953), is an established aberration, in the light of the Court's holding that other interstate professional sports are not similarly exempt, but one in which Congress has acquiesced, and that is entitled to the benefit of stare decisis.

Analysis

The court applied the established precedent that professional baseball is exempt from federal antitrust laws. It noted that the reserve clause is integral to the organization of baseball as a league sport, and the evidence presented did not favor its elimination. The court emphasized that any inconsistencies or issues with the reserve system should be addressed by Congress, not the courts.

Removal of the resultant inconsistency at this late date is a matter for legislative, not judicial, resolution.

Conclusion

The Supreme Court affirmed the lower court's ruling, maintaining that professional baseball's reserve system is exempt from federal antitrust laws.

Held: The longstanding exemption of professional baseball from the antitrust laws is an established aberration in which Congress has acquiesced and is entitled to benefit of stare decisis.

Who won?

The prevailing party in this case was the defendants, which included the Commissioner of Baseball and the major league clubs. The court upheld the longstanding exemption of professional baseball from federal antitrust laws, emphasizing that this exemption is a matter of legislative, not judicial, resolution. The court's decision reinforced the idea that the reserve clause, while potentially restrictive, is a necessary component of the league's structure and that any changes should be made through Congress.

The defendants prevailed in this case as the court affirmed the lower court's ruling, maintaining that the reserve system is exempt from federal antitrust laws. The court emphasized that any changes to this system should be addressed by Congress, not the judiciary.

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