Chicago National Ball Club, Inc. v. Vincent

No. 92 C 4398 (1992)

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Chicago National Ball Club, Inc. v. Vincent

United States District Court for the Northern District of Illinois
No. 92 C 4398 (1992)

Facts

The Chicago National League Ball Club, Inc. (Cubs) (plaintiff) was a member of the National League (NL) within Major League Baseball (MLB). Starting with the 1968 season, the Cubs played in the NL’s eastern division. However, by 1992, certain NL clubs sought to realign the league’s divisions, which would have moved the Cubs to the western division. On March 4, 1993, the NL’s clubs voted 10-2 in favor of realignment, with the Cubs voting against realignment. The Cubs’ vote meant the proposal was defeated pursuant to § 9.4 of the NL’s constitution, which provided that a club could not be moved to another division without its consent. On July 6, Francis T. Vincent, MLB’s commissioner, issued an order implementing a realignment of the NL’s divisions, including moving the Cubs to the western division. Vincent asserted authority to override the NL’s rejection of realignment pursuant to his power under Article I of the Major League Agreement (MLA) to investigate any action or conduct that was not in the best interests of baseball and to take necessary action, such as remedial, preventive, punitive action. Per Vincent, the requirement that the Cubs approve a division transfer was not in baseball’s best interests because most NL clubs favored realignment. The Cubs brought an action for declaratory and preliminary and permanent injunctive relief under Illinois law against the forced realignment. The Cubs argued that Vincent exceeded his power under Article I and that MLA Article VII barred the commissioner from resolving disputes whose resolution otherwise was addressed by the NL’s constitution.

Rule of Law

Issue

Holding and Reasoning (Conlon, J.)

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