Federal Baseball Club of Baltimore, Inc. v. National League of Professional Baseball Clubs

Background

A Maryland-incorporated baseball club that belonged to the rival Federal League sued the established National and American Leagues and several league officials. The club said the two big leagues conspired to destroy the Federal League by buying or inducing member clubs to leave, causing heavy losses. The club won a jury verdict for $80,000 and a treble-damage judgment, but the Court of Appeals held the leagues were not covered by the federal antitrust law and ordered judgment for the defendants.

Reasoning

The Court addressed whether staging professional baseball games across cities is “commerce among the States” under the Sherman Act. The opinion reasons that the business is giving baseball exhibitions, which are essentially local affairs, and that the travel of players or officials across state lines is only an incident. The Court relied on the distinction that transport for an exhibition does not transform a noncommercial local service into interstate commerce, citing examples like a lawyer or a traveling lecturer. Because the exhibitions themselves are not commerce among the States, the federal antitrust statute does not apply to the leagues’ conduct.

Real world impact

The decision means organized baseball’s arrangement of games and related restraints will not, under this opinion, be treated as interstate commerce subject to the Sherman Act. Rival clubs seeking treble damages for the leagues’ conduct cannot rely on that federal antitrust statute here. The ruling turns on the characterization of baseball as exhibitions rather than interstate trade and affirms judgment for the leagues and officials.