Butterworth v. National League of Professional Baseball Clubs
Florida Supreme Court
644 So. 2d 1021 (1994)
- Written by Steven Pacht, JD
Facts
A group of investors (Tampa investors) sought to purchase the San Francisco Giants (club) and move the club to Tampa Bay, Florida, but Major League Baseball (MLB) vetoed the transaction. Instead, other investors bought the club and kept it in San Francisco. Robert Butterworth (plaintiff), Florida’s attorney general, commenced an investigation into potential violations of federal and Florida antitrust law regarding the sale and purchase of the club. In connection with this investigation, Butterworth issued civil investigative demands (CIDs) to the National League of Professional Baseball Clubs (league) (defendant) and William White, the league’s president. The league petitioned the Florida circuit court to set aside the CIDs, arguing that MLB was immune from federal and Florida antitrust law based on the United States Supreme Court’s decisions in Federal Baseball Club of Baltimore, Inc. v. National League of Professional Baseball Clubs, Toolson v. New York Yankees, Inc., and Flood v. Kuhn. The circuit court agreed with the league, ruling that the ownership and location of MLB teams were not subject to federal or Florida antitrust law. Butterworth appealed to the district court, arguing that MLB was immune from federal and Florida antitrust law only with respect to MLB’s player-reserve clause. The district court confirmed the circuit court’s order. However, the district court also certified a question to the Florida Supreme Court regarding the scope of MLB’s immunity from federal and Florida antitrust law.
Rule of Law
Issue
Holding and Reasoning (Harding, J.)
Dissent (McDonald, J.)
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