Atlanta National League Baseball Club v. Kuhn

432 F. Supp. 1213 (1977)

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Atlanta National League Baseball Club v. Kuhn

United States District Court for the Northern District of Georgia
432 F. Supp. 1213 (1977)

Facts

Pursuant to the collective-bargaining agreement (CBA) between Major League Baseball (MLB) and the players’ union, certain players could become free agents at the end of the 1976 season. MLB’s commissioner, Bowie Kuhn (defendant), issued six directives warning clubs and players against tampering with free agents. For example, Kuhn warned the clubs against indirect communications with free agents via media statements about how much a free agent might be paid. One directive further warned that violators could be suspended or lose picks in MLB’s player drafts. On October 5, Kuhn ruled that an employee of the Atlanta Braves (Braves) (plaintiff), tampered with a free agent, Gary Matthews of the San Francisco Giants (Giants), for which Kuhn fined the Braves $10,000 and stripped the club of a pick in the amateur draft. On October 20, Ted Turner (plaintiff), the Braves’ chief executive officer, told the Giants’ owner—with the media present—that he would pay whatever was necessary to sign Matthews, leading Kuhn to suspend Turner for one year. Turner and the Braves sued Kuhn, arguing, among other things, that Kuhn was not authorized to issue the directives because Kuhn had rulemaking authority regarding only procedural issues and that Turner’s suspension and the draft-pick deprivation were improper. Kuhn responded that, among other things, (1) the Major League Agreement (MLA), to which Turner and the Braves were bound, waived their right to judicially challenge MLB-imposed discipline; (2) the MLA authorized him to issue the directives in pursuit of the best interests of baseball; (3) Turner’s suspension was proper given the two instances of misconduct regarding Matthews despite Kuhn’s six directives; and (4) the MLA authorized the draft-pick sanction despite not including that penalty on a list of possible punishments because the MLA list was not exhaustive.

Rule of Law

Issue

Holding and Reasoning (Edenfield, J.)

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