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Keywords

contractlawsuitdefendantstatutetrustantitrustcivil rights
contractplaintiffdefendanttrustantitrust

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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 Flood, a prominent center fielder, was traded from the St. Louis Cardinals to the Philadelphia Phillies without his consent in 1969. Following the trade, Flood requested to be made a free agent, which was denied by the Commissioner of Baseball. Flood subsequently filed an antitrust lawsuit against the Commissioner and the major league clubs, claiming violations of federal antitrust laws and civil rights statutes, seeking both declaratory and injunctive relief.

The petitioner, Curtis Charles Flood, born in 1938, began his major league career in 1956 when he signed a contract with the Cincinnati Reds for a salary of $4,000 for the season. He was traded to the St. Louis Cardinals before the 1958 season. Flood rose to fame as a center fielder with the Cardinals during the years 1958—1969. In October 1969, Flood was traded to the Philadelphia Phillies of the National League in a multi-player transaction. He was not consulted about the trade. He was informed by telephone and received formal notice only after the deal had been consummated.

Issue

Whether the reserve clause in Major League Baseball, which restricts players' ability to negotiate contracts freely, is subject to federal antitrust laws.

Whether the reserve clause in Major League Baseball, which restricts players' ability to negotiate contracts freely, is subject to federal antitrust laws.

Rule

The Supreme Court ruled that professional baseball's reserve system is exempt from federal antitrust laws, a status established by previous cases and accepted by Congress.

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 principle of stare decisis, referencing earlier rulings in Federal Baseball Club v. National League and Toolson v. New York Yankees, which established that baseball is not considered interstate commerce under antitrust laws. The Court noted that Congress has had ample opportunity to legislate against this exemption but has chosen not to do so, thus reinforcing the existing legal framework.

The Court thus chose not to be persuaded by opposing examples proffered by the plaintiff, among then (a) Judge Learned Hand's decision on a demurrer to a Sherman Act complaint with respect to vaudeville entertainers traveling a theater circuit covering several States, H. B. Marienelli, Ltd. v. United Booking Offices, 227 F. 165 (S.D.N.Y.1914); (b) the first Mr. Justice Harlan's opinion in International Textbook Co. v. Pigg, 217 U.S. 91, 30 S.Ct. 481, 54 L.Ed. 678 (1910), to the effect that correspondence courses pursued through the mail constituted commerce among the States; and (c) Mr. Justice Holmes' own opinion, for another unanimous Court, on demurrer in a Sherman Act case, relating to cattle shipment, the interstate movement of which was interrupted for the finding of purchasers at the stockyards, Swift & Co. v. United States, 196 U.S. 375, 25 S.Ct. 276, 49 L.Ed. 518 (1905).

Conclusion

The Supreme Court affirmed the lower court's ruling, maintaining that the reserve clause is not subject to federal antitrust laws and that any changes must come from legislative action.

Held: 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.

Who won?

The defendants, including the Commissioner of Baseball and the major league clubs, prevailed because the Court upheld the exemption of baseball from antitrust laws, citing the need for legislative rather than judicial resolution of the issue.

The defendants (although not all were named in each cause of action) were the Commissioner of Baseball, the presidents of the two major leagues, and the 24 major league clubs.

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