Federal Baseball - 1922 (FEDERAL BASEBALL CLUB OF BALTIMORE, INC. v. NATIONAL LEAGUE OF PROFESSIONAL BASEBALL CLUBS, ET AL. )
Court of Appeals
Supreme Court
Background: The Federal League of Professional Baseball Clubs was a professional baseball league rivaling with the National and American Leagues of Professional Baseball Clubs. The league was organized in 1913, then was dissolved in 1915 after an agreement was reached with the National and American Leagues. The Federal League team in Baltimore refused to be a party to the agreement and brought suit against the National and American Leagues claiming that the National League violated the Sherman Antitrust Act. The case was tried in the Supreme Court of the District of Columbia, which found for the Federal League Baltimore Club; then appealed to the Court of Appeals of the District of Columbia, which reversed the decision; then appealed again to the Supreme Court of the United States, which upheld the decision of the appellate court.
Result: The Supreme Court upheld the ruling of the Court of Appeals and determined that baseball did not classify as interstate commerce, that travel across state lines was incidental. Therefore, baseball was exempt from United States antitrust legislation. This exemption remains today.
Toolson v. New York Yankees - 1953 (TOOLSON v. NEW YORK YANKEES, INC. ET AL.)
Background: George Toolson was a minor league player in the Yankees organization. In 1951, Toolson brought suit against the New York Yankees in District Court in Southern California alleging that the team had violated antitrust laws by using the reserve clause to keep him in the minor leagues and preventing a promotion to the majors. The case was heard by the Supreme Court and decided in November, 1953.
Result: The Supreme Court chose to uphold the 1922 ruling exempting Major League Baseball from antitrust law. The court decided that if the ruling is to be changed, it needs to be changed by Congress.
Flood v. Kuhn - 1972 (FLOOD v. KUHN ET AL.)
District Court
Court of Appeals
Supreme Court
Background: In 1969, the St. Louis Cardinals traded Curt Flood to the Philadelphia Phillies after 12 solid seasons with the Cardinals, including three All-Star appearances and seven Gold Gloves. Flood was opposed to the trade and chose to sue Major League Baseball over the reserve clause, claiming that he was being treated like a slave. Major League Baseball was again tried based on antitrust violations.
Result: The Supreme Court ruled against Curt Flood in 1972. However, the reserve clause basically ended when owners introduced salary arbitration later in 1972 and free agency a few years later. Curt Flood never played professional baseball again.