FEDERAL BASEBALL CLUB OF BALTIMORE, INC. v. NATIONAL LEAGUE OF PROFESSIONAL BASEBALL CLUBS ET AL.
The Federal Baseball Club of Baltimore, Maryland was a baseball club and a member of the Federal League of Professional Base Ball Players. The National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs conspired to monopolize the business of professional baseball by buying out members of the Federal League and by inducing members of the Federal League to leave.
The Federal Baseball Club of Baltimore brought suit in the Supreme Court for the District of Columbia against the other leagues under the Sherman Act and obtained a verdict for $80,000. On appeal, the Court of Appeals of the District of Columbia reversed the lower court's ruling and held that the defendant baseball leagues were not within the Sherman Act's purview. The Federal Baseball Club of Baltimore appealed to the U.S. Supreme Court.
Are the activities of the National League of Professional Base Ball Clubs and the American League of Professional Base Ball Clubs subject to the Sherman Act?
No. Writing for a unanimous Supreme Court, Justice Oliver Wendell Holmes affirmed the decision of the Court of Appeals. The Supreme Court held that the baseball leagues were not engaging in interstate trade or commerce as defined by the Sherman Act because the exhibition that is a baseball game is not trade or commerce as those terms were commonly understood. As such, the baseball leagues were not subject to the Sherman Act.