Thursday, November 7, 2013

American League Baseball Club of Chicago v. Chase case brief

American League Baseball Club of Chicago v. Chase case brief summary
149 N.Y.S. 6 (1914)

Defendant baseball player moved for an order dissolving the temporary injunction which restrained player from playing baseball for anyone other than plaintiff club during the period of player's contract with the club.

Baseball player signed a contract to play with club which he subsequently cancelled by notification to club. Player then signed to play with a rival club.

  • The court held that 
  • (1) the jurisdiction of equity was clear in the case, 
  • (2) player was reputed to possess special, unique and extraordinary characteristics as a baseball player,
  • (3) player's contract, together with the national agreement and the rules of the national commission adopted pursuant to that agreement, had to be considered as evidencing the general agreement or plan regulating the employment and conduct of player as a national agreement player, 
  • (4) the absolute lack of mutuality, both of obligation and of remedy, in the contract, would prevent a court of equity from making it the basis of equitable relief by injunction or otherwise, 
  • (5) the negative covenant was without a consideration to support it, and was unenforceable by injunction, 
  • (6) baseball was not a commodity or an article of merchandise subject to the regulation of congress on the theory that it was interstate commerce, and
  • (7) organized baseball was now as complete a monopoly of the baseball business for profit as any monopoly could be made.


The motion was granted.

Suggested Study Aid For Sports Law

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