Flood V. Kuhn - Whether Professional Baseball’s Reserve System Violates Federal Anti-Trust Laws?

CASE #1: Flood v. Kuhn

Issues: Whether professional baseball’s reserve system violates federal anti-trust laws?

Rule: A player cannot bring an antitrust claim challenging the sport’s reserve system against Major League Baseball.

Analysis: Baseball was engaged in big business and interstate commerce but was an anomaly due to its exemption from anti-trust laws. In the last 50 years, five consecutive cases were granted stare decisis. Beginning with Federal Baseball v. National League, it was noted that there was a need for the reserve clause and no feasible substitutes were available to protect the integrity of the game. The court adhered to the same principle and felt if action needed to take place it should be remedied by the Congress and not the court. Under this analysis, the court affirmed the lower court based on precedent.

Conclusion: No, baseball’s reserve system is exempt from federal anti-trust laws.

CASE #2: Silverman v. Major League Baseball Player Relations Committee

Issues: Whether Major League Baseball owners violated the duty to bargain collectively in good faith with the players? Whether the NLRB has reasonable cause to believe that the unilateral changes made by the owners were to mandatory provisions? If upheld, is the injunctive relief just and proper?

Rule: Parties must honor the terms and conditions of the expired contract that involve mandatory subjects of bargaining.

Analysis: When owners declared an impasse on December 22, 1994, they also announced that a salary cap would be imposed along with the removal of salary arbitration. This affected individual’s wages. These labor practices were unfair and violated collective bargaining matters by not honoring mandatory provisions in the previous agreement. Public interest and the players would also be irreparably harmed if an injunction were not issued. This case has greatly become about federal law and collective bargaining on trial. The labor laws must be followed within good spirit. Furthermore, without an injunction the bargaining possibility to continue negotiations in good faith would be diminished.

Conclusion: Yes, the NLRB did have reasonable cause to believe the Owners engaged in unfair labor practices and temporary injunctive relief is granted. The provisions expected to change were mandatory subjects and injunctive relief was warranted.

CASE #3: Mackey v. National Football League

Issues: Whether the labor exemption to the antitrust laws immunizes the NFL’s enforcement of the Rozelle Rule from antitrust liability? Whether the Rozelle Rule and its enforcement violate antitrust laws?

Rule: A non-labor group engaging in collective bargaining can be exempt from antitrust laws if there were prior agreements concerning specific rules. Restraints on competition within the market for players’ services are violations of the Sherman Act.

Analysis: The NFL was not granted immunization because there was no evidence to suggest that the Rozelle Rule was agreed upon in either of the previous CBA’s. Thus, the NFL’s Rozelle Rule would be considered a mandatory subject of collective bargaining and be held to antitrust laws. The Rozelle Rule operates to deter teams from signing free agents and a club will only sign that free agent where it reaches a deal with the player’s former team. The rule was overly broad and unreasonable. It greatly affected the bargaining capability of the players. Additionally, removing the Rozelle Rule would not disrupt