Question

Case brief for Business Law

Federal Baseball Club v. National League, 259 U.S. 200 (1922)

FACT:?

ISSUE?

RULE OF LAW?

COURT'S REASONING ?

CONCLUSION?

Source?

Answer 1

Federal Baseball Club v. National League, 259 U.S. 200 (1922)

Case Brief :-

FACTS :-

The Federal Baseball Club of Baltimore (“club”) , Maryland was a baseball club and a member of the Federal League of Professional Base Ball Players. The National League of Professional Base Ball Clubs (“National League”) and the American League of Professional Base Ball Clubs conspired to monopolize the business of professional baseball by buying out members of the Federal League and by inducing members of the Federal League to leave. Great damage to the plaintiff is alleged.

The Federal Baseball Club of Baltimore brought an antitrust action suit in the Supreme Court for the District of Columbia against the other leagues (i.e. The National League of Professional Base Ball Clubs)alleging that they had conspired to monopolize the baseball business by purchasing or otherwise inducing all other clubs in the club's former league to leave that league under the Sherman Act. At trial, 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.
On appeal, however, after an ellaborate discussion the Court of Appeals of the District of Columbia reversed the lower court's ruling and held that the defendant baseball leagues were not within the Sherman Act's purview. The Federal Baseball Club of Baltimore appealed to the U.S. Supreme Court.

ISSUE :- The question with which the court is here concerned is whether the business in which the defendants were engaged when the wrongs complained of occurred, taken as an entirety, was interstate commerce, or more accurately, whether the monopoly which they had established or attempted to establish was a monopoly of any part of interstate commerce.
Did National League’s monopoly interfere with interstate commerce? Are the activities of the National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs subject to the Sherman Act?

Rule Of Law :- Professional baseball is a business. The business of giving exhibitions of baseball is purely a state affair. The fact that in order to give the exhibitions the baseball leagues must induce free persons to cross state lines and must arrange and pay for their doing so is not enough to change the character of the business.

COURT'S REASONING :-

The Supreme court characterized the baseball as an exhibition, and although it was a business, it was not a subject of commerce.

In its detailed judgement and in the consequent reasonings, the court started with emphasizing on the fact that the decision of the Court of Appeals went to the root of the case. The judgement reasoned that the clubs composing the Leagues were in different cities and for the most part in different states. As per the presentations of evidence by both the plaintiff and the defendents, it can be easily understood that the job of these clubs was to play against one another in public exhibitions for money, one or the other club crossing a state line in order to make the meeting possible. When, as the result of these contests, one club had won the pennant of its league and another club had won the pennant of the other league, there was a final competition for the world's championship between these two. Of course, the entire scheme requires constantly repeated traveling on the part of the clubs, which was provided for, controlled, and disciplined by the organizations, and this, actually implied, commerce among the states. But the court was of the opinion that the Court of Appeals was right in its decision.

The court raesoned that, the business was giving exhibitions of baseball, which were purely state affairs. It was also true that, in order to attain for these exhibitions the great popularity that they had achieved, competitions must be arranged between clubs from different cities and states. But the fact that, in order to give the exhibitions, the Leagues must induce free persons to cross state lines and must arrange and pay for their doing so was not enough to change the character of the business. According to the distinction insisted upon in Hooper v. California, 155 U. S. 648, 155 U. S. 655, the transport was a mere incident, not the essential thing. Thus it ac be inferred that, the exhibition, although made for money, would not be called trade of commerce in the commonly accepted use of those words.

The court supported the defendents argument that, personal effort put up by the parties for the successfull completion of the league, was not related to production & hence not a subject of commerce. Thus mere transportation among state did'nt constitute interstate commerce. The court gave an illustration while reasoning its judgement that, a firm of lawyers sending out a member to argue a case, did'nt not engage in such commerce because the lawyer went to another state.

Hence, the court described the plaintiff's business in the same way, and inferred by saying, that the restrictions by contract that prevented the plaintiff from getting players to break their bargains and the other conduct charged against the defendants were not an interference with commerce among the states.

Conclusions :- Writing for a unanimous Supreme Court, Justice Oliver Wendell Holmes affirmed the decision of the Court of Appeals. The Court held that that the conduct charged against National League was not an interference with interstate commerce, as prohibited by the Sherman Act. Although competitions between the various clubs required extensive and frequent travel across state lines of players and officials, such travel was merely incidental to the baseball competitions. The baseball competitions were not commerce, and thus, baseball was purely a state affair. As a state affair, the professional baseball business was not subject to federal antitrust law.