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City of San Jose v. Office of the Commissioner of Baseball
United States Court of Appeals for the Ninth Circuit
776 F.3d 686 (2015)
Major League Baseball (MLB) (defendant) required each of its 30 member clubs, or franchises, to play their home games within a designated territory. The Oakland Athletics team (the Athletics) was required to play in the counties of Alameda and Contra Costa. The Athletics wanted to move to the City of San Jose (plaintiff), but San Jose fell within the territory of the San Francisco Giants. A franchise was not allowed to relocate to another franchise’s territory without the approval of at least three-quarters of MLB’s clubs. The Athletics entered an option to purchase land in San Jose. The MLB began investigating the implications of a move, but the process dragged on. No approval was forthcoming, and San Jose believed that MLB was trying to maintain a local monopoly. San Jose sued MLB under various laws, including state and federal antitrust laws. The district court granted MLB’s motion to dismiss the antitrust claims based on the baseball industry’s historic exemption from antitrust laws. San Jose appealed.
Rule of Law
Holding and Reasoning (Kozinski, J.)
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