Friday, November 8, 2013

Flood v. Kuhn case brief

Flood v. Kuhn case brief summary
407 U.S. 258 (1972)

Certiorari was granted in order to review the decision of the United States Court of Appeals for the Second Circuit, in plaintiff baseball player's action against defendants seeking a ruling that professional baseball's reserve system fell within the scope of the federal antitrust laws.


  • The Supreme Court found that plaintiff baseball player could not bring an antitrust claim challenging the sport's reserve system against defendant Commissioner of Baseball, the presidents of the two leagues he was traded between, and the major league clubs. 
  • Although baseball was a big business engaged in interstate commerce, precedent dictated that the reserve system was exempt from federal antitrust laws.
  • In this regard, baseball was anomalous among professional sports, but Congress had the power to change the nature of the sport through legislation.
  • Plaintiff's state law claims failed because granting the relief sought would conflict with federal policy and national uniformity.


The Supreme Court affirmed the lower court judgment against plaintiff, based on precedent exempting baseball's reserve system from antitrust laws; Congress had multiple opportunities to end baseball's exemption from the antitrust laws.

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