''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 The Sherman Antitrust Act of 1890 (, ) is a United States antitrust law which prescribes the rule of free competition among those engaged in commerce. It was passed by Congress and is named for Senator John Sherman, its principal author. ...

did not apply to

Major League Baseball Major League Baseball (MLB) is a professional baseball organization and the oldest major professional sports league in the world. MLB is composed of 30 total teams, divided equally between the National League (NL) and the American League (A ...

Background

After the

Federal League The Federal League of Base Ball Clubs, known simply as the Federal League, was an American professional baseball league that played its first season as a minor league in 1913 and operated as a "third major league", in competition with the e ...

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 Terriers The St. Louis Terriers were a baseball club that played in the short-lived Federal League in and . They played their home games at Handlan's Park. The team was owned by ice magnate Phil Ball, who later was owner of the St. Louis Browns. In thei ...

of the Federal League had been permitted to buy the St. Louis Browns of the

American League The American League of Professional Baseball Clubs, known simply as the American League (AL), is one of two leagues that make up Major League Baseball (MLB) in the United States and Canada. It developed from the Western League, a minor league b ...

. The owner of the Baltimore Terrapins had not been compensated, and sued the

National League The National League of Professional Baseball Clubs, known simply as the National League (NL), is the older of two leagues constituting Major League Baseball (MLB) in the United States and Canada, and the world's oldest extant professional team s ...

, the

and other defendants, including several Federal League officials for conspiring to monopolize baseball by destroying the Federal League. In 1919, the defendants were found jointly liable, and damages of $80,000 assessed, which was tripled to $240,000 under the provisions of the Clayton Antitrust Act.

Judgment

Court of Appeals

The Court of Appeals reversed the trial verdict, and held that baseball was not subject to the Sherman Act. The case was appealed to the Supreme Court.

Supreme Court

In a unanimous decision written by Justice Oliver Wendell Holmes, 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 The Commerce Clause describes an enumerated power listed in the United States Constitution ( Article I, Section 8, Clause 3). The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and amo ...

for the purposes of the Sherman Act. Justice Holmes' decision was as follows:

Significance

This case is the main reason why MLB has not faced any competitor leagues since 1922, and MLB, to date, remains the only American sports league with such an antitrust exemption. The case was reaffirmed in '' Toolson v. New York Yankees, Inc. '' In ''

Flood v. Kuhn ''Flood v. Kuhn'', 407 U.S. 258 (1972), was a decision by the Supreme Court of the United States that preserved the reserve clause in Major League Baseball (MLB) players' contracts. By a 5–3 margin, the Court reaffirmed the antitrust exemptio ...

'', the Court partially reversed, and found Major League Baseball to be engaged in interstate commerce. However, the justices refused to overturn baseball's original antitrust exemption from ''Federal Baseball'', deeming it necessary to preserve precedent: in addition to ''Toolson'', the case had already been heavily cited in ''Shubert'', '' International Boxing'', and '' Radovich''. In 2016's '' Direct Marketing Association v. Brohl'', the 10th Circuit's

Neil Gorsuch Neil McGill Gorsuch ( ; born August 29, 1967) is an American lawyer and judge who serves as an associate justice of the Supreme Court of the United States. He was nominated by President Donald Trump on January 31, 2017, and has served since ...

cited ''Federal Baseball'' and ''Toolson'' in his concurrence as one of the "precedential islands _along_with_''Bellas_Hess'',_that.html" ;"title="Bellas_Hess.html" ;"title=" along with ''Bellas Hess"> along with ''Bellas Hess'', that">Bellas_Hess.html" ;"title=" along with ''Bellas Hess"> along with ''Bellas Hess'', thatmanage[s] to survive indefinitely even when surrounded by a sea of contrary law…. [that] would never expand but would, if anything, wash away with the tides of time". N.B: Two years later, Associate Justice Gorsuch would wash away the ''Bellas Hess'' "precedential island" in the ''Wayfair'' decision.

References

External links

* {{Federal League History of Major League Baseball United States Supreme Court cases United States Supreme Court cases of the Taft Court United States antitrust case law Baseball law Federal League 1922 in United States case law Baltimore Terrapins Major League Baseball litigation