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Keywords

contractprecedentappealtrustclass actionantitrust

precedenttrustantitrust

Related Cases

Miranda v. Selig, 860 F.3d 1237, 167 Lab.Cas. P 36,544, 2017-1 Trade Cases P 80,036, 17 Cal. Daily Op. Serv. 6135, 2017 Daily Journal D.A.R. 6191

Facts

Minor league baseball players filed a class action against the Office of the Commissioner of Baseball and MLB franchises, claiming violations of federal antitrust laws by restraining competition and depressing salaries. The players alleged that they earned significantly less than their major league counterparts and received no salary during spring training. The district court dismissed the action, ruling that the business-of-baseball exemption to antitrust laws applied. The players appealed the dismissal.

Issue

Whether the business-of-baseball exemption to federal antitrust law precludes minor league players' action against Major League Baseball.

Rule

The business-of-baseball exemption, established by precedent, exempts the business of baseball from federal antitrust laws. This exemption applies to the employment of minor league players, as their contracts and employment practices are integral to the business of providing public baseball games for profit. The Curt Flood Act maintains this exemption for minor league baseball.

Analysis

The court analyzed the employment contracts of minor league players, noting that they are employed by MLB franchises and that their contracts include a reserve clause, which restricts their ability to play for other teams. The court emphasized that the historical context of the business-of-baseball exemption, upheld by the Supreme Court, applies to minor league baseball as well. The players' claims were found to be implausible under the established legal framework.

Conclusion

The Court of Appeals affirmed the district court's dismissal of the players' action, holding that the business-of-baseball exemption precludes their claims under federal antitrust law.

In light of Supreme Court precedent, the decisions of our Court, and the Curt Flood Act, minor league baseball falls squarely within the nearly century-old business-of-baseball exemption from federal antitrust laws.

Who won?

The prevailing party in this case was Major League Baseball and its franchises. The court ruled in favor of MLB, affirming the district court's decision to dismiss the players' claims. The court reasoned that the business-of-baseball exemption, which has been upheld by the Supreme Court for nearly a century, applies to the employment practices of minor league players, thereby precluding the players' antitrust claims.

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