Toolson v. New York Yankees | |
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Argued October 13, 1953 Decided November 9, 1953 | |
Full case name | George Earl Toolson v. New York Yankees, Inc., et al. |
Citations | 346 U.S. 356 (more) |
Case history | |
Prior | Cert. to the United States Court of Appeals for the Ninth Circuit |
Holding | |
Congressional intent to maintain antitrust exemption for professional baseball created by prior Court presumed as a result of congressional inaction since that decision; proper remedy is thus legislative action. Ninth Circuit affirmed. | |
Court membership | |
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Case opinions | |
Per curiam | |
Dissent | Burton, joined by Reed |
Laws applied | |
Sherman Antitrust Act |
Toolson v. New York Yankees, 346 U.S. 356 (1953), is a United States Supreme Court case in which the Court upheld, 7–2, the antitrust exemption first granted to Major League Baseball (MLB) three decades earlier in Federal Baseball Club v. National League. It was also the first challenge to the reserve clause which prevented free agency,[1] and one of the first cases heard and decided by the Warren Court.
Since it presumed that Congress's failure to act in the years since Federal Baseball Club was an implicit expression of intent to keep baseball exempt from the Sherman Antitrust Act, it has been read as having done more to create that exemption than the older case. Two justices (Stanley Forman Reed and Harold Hitz Burton) dissented from the short, unsigned per curiam majority opinion, arguing MLB and its revenue sources had changed enough since 1922 that the logic of that case no longer applied. In 1972, a third justice (William O. Douglas) would express his regret at having joined the majority when Toolson was again upheld in the similar Flood v. Kuhn.
Toolson had been placed on the ineligible list after he refused to accept a demotion from Triple-A Newark to Binghamton of the Eastern League, which was a lower classification team. Major league clubs would keep top talent in the minors as protection against being caught short-handed if top talent was injured. Toolson, who probably could have played for a number of other major-league teams, found himself in that situation. He believed he was being denied the opportunity to play in the majors because of the depth of the Yankees' farm system.