Federal League Baseball Club of Baltimore v National League et al. 259 US 200 (1922)

  • Roger I. Abrams
Part of the ASSER International Sports Law Series book series (ASSER)


The claimant, a baseball club, sought review of a decision of the United States Court of Appeals of the District of Columbia, which reversed a judgment awarding the club damages for a conspiracy by the defendants to monopolise the baseball industry in violation of federal antitrust/competition law, namely the Sherman Act 1890. The claimants alleged that the defendants had conspired by purchasing or inducing all other clubs in the claimant’s former league to leave that league. The United States Supreme Court affirmed the decision of the US Court of Appeals and held that the conduct charged against the defendants was not an interference with interstate commerce as prohibited by, and within the meaning of, the Sherman Act. The US Supreme Court’s rationale was that, although competitions between the various clubs required extensive and repeated travel across state lines by players and officials, such travel was merely incidental to baseball competitions. The business of providing and organising public baseball games for profit between professional clubs in rival league formats was not interstate commerce: baseball was purely a state affair and thus America’s “national game” was not subject to federal antitrust law.


State Line Reserve System Professional Baseball National League Interstate Commerce 
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Copyright information

© T.M.C. ASSER PRESS, The Hague, The Netherlands, and the author(s) 2013

Authors and Affiliations

  1. 1.Richardson Professor of Law, School of LawNortheastern UniversityBostonUSA

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