American League Baseball Club of New York v. Johnson

Carl W. Mays was a pitcher for the Boston Red Sox (Boston). On July 13, 1919, Mays was unhappy due to personal issues, he pitched poorly, and his mood did not improve when he was struck by a ball thrown by a teammate. Mays left the game shortly thereafter, and Boston’s manager, Edward Barrow, allowed Mays to leave and seek medical attention. On July 23, Ban Johnson (defendant), the league’s president, purportedly telegrammed Barrow that Boston should suspend Mays and also notified the American League Baseball Club of New York (New York) (plaintiff) that Mays needed to be punished. On July 29, after being away from the team, Mays told Boston’s owner that he had a nervous breakdown but was ready to return. The same day, Boston assigned Mays’s contract to New York. Upon discovering the assignment on July 31, Johnson suspended Mays indefinitely. New York sued Johnson, seeking to preliminarily enjoin the suspension. Johnson claimed he suspended Mays to punish Boston and New York for their assignment of Mays’s contract and was authorized to do so by the league constitution. Yet § 36 of the constitution authorized only the league’s board of directors, not its president, to punish clubs. Johnson also claimed authority to punish Mays under §§ 20 and 24 of the league constitution. Section 20 empowered him, in the performance of his duties, to suspend a player for conduct detrimental to the game. The constitution was silent as to Johnson’s duties regarding on-field conduct, but the league’s playing rules authorized him to punish violators via suspension. Section 24 gave the clubs the right to regulate their own affairs, including by disciplining players for carelessness, indifference, or other conduct the club might consider prejudicial to its interests but not in conflict with baseball’s national agreement or the league constitution. Citing the not-in-conflict clause, Johnson claimed that a club’s § 24 power was subject to his general rights under § 20. Finally, Johnson argued that because no one challenged his numerous prior disciplinary actions against players, all parties acquiesced to his authority to take such action.