Citations 259 U.S. 200 (more) | End date 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. Majority Holmes, joined by unanimous Similar Flood v Kuhn, United States v E C Knight, O'Bannon v NCAA, Wickard v Filburn | ||
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.
Contents
Facts
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.
Court of Appeals
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.
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:
Significance
The decision was reaffirmed in Toolson v. New York Yankees, 7 to 2, and Flood v. Kuhn, 5 to 3.