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Alvin Moore & Atlanta Braves

Major League Baseball Arbitration Proceeding
MLB-MLBPA Arb. 77-18 (1977)


Alvin Moore (plaintiff) signed a one-year contract with the Atlanta Braves. The contract contained a clause that said if Moore was not satisfied with his playing time, the Braves were required to trade him to a team approved by Moore. The covenant also stated that if a trade were not completed by the end of the season, Moore was allowed to become a free agent if he so chose. At the time, Moore had less than one year of service in Major League Baseball (MLB). The league president (defendant) disapproved of this covenant. The president believed that the covenant was inconsistent with the collective-bargaining agreement agreed to by the league and the players’ union. This agreement required players to have a minimum of five years of service in MLB before they could become eligible for free agency. The players’ union filed a grievance on Moore’s behalf. The union cited the collective-bargaining agreement’s clause permitting special covenants that benefit players. The union maintained that the president could disapprove of a special covenant only if the covenant did not benefit the player. The league countered that this covenant effectively created an entirely new reserve system, contrary to what the league and players had previously agreed to. According to the league, the reserve system created by the collective-bargaining agreement was created to provide for an even and equitable distribution of players among all of the teams. Additionally, the collective-bargaining agreement contained a free agent re-entry procedure. By giving Moore the ability to determine his own free agency, the league argued, the covenant contravened the agreed-upon system. The league contended that a covenant that violated the collective-bargaining agreement and the rights of the other 25 MLB teams could not be permitted to stand simply because it benefited a player. The issue was brought before an arbitrator.

Rule of Law


Holding and Reasoning (Porter, A.)

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