Saturday, November 9, 2013

Piazza and Tirendi v. Major League Baseball case brief

Piazza and Tirendi v. Major League Baseball case brief summary
831 F.Supp. 420 (1993)

Defendant baseball clubs moved for dismissal under Fed. R. Civ. P. 12(b)(1) and 12(b)(6), for an order dismissing plaintiff investors' federal antitrust, constitutional, and state law claims brought for defendants' alleged interference with plaintiffs' attempted purchase and relocation of a professional baseball team.

Plaintiffs filed suit after defendant baseball clubs refused to allow plaintiffs' purchase and relocation of a professional baseball team. Defendants moved to dismiss plaintiffs' claims of federal antitrust violations, constitutional due process and equal protection violations, violations of 42 U.S.C.S. § 1983 and state law claims of slander, libel, invasion of the right of privacy, false light, tortious interference with existing and prospective contractual business relations, unlawful restraint of trade, and civil conspiracy. Defendants claimed an exemption from antitrust liability, but the court concluded that the exemption was limited to baseball's reserve system.


  • The court dismissed plaintiffs' direct constitutional claims because plaintiffs did not offer requisite evidence that defendants' actions were authorized by the government, despite the limited exemption from antitrust laws. 
  • However, the court concluded that plaintiffs pleaded sufficient facts to conclude that defendants may have acted under color of state law, so as to support a claim under 42 U.S.C.S. § 1983.

The court dismissed plaintiffs' direct claims under the U.S. Constitution because plaintiffs failed to show direct government action. The court denied defendants' motion to dismiss in all other respects and retained supplemental jurisdiction over plaintiffs' state law claims.

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