Griffin v. Brooklyn Ball Club

73 N.Y.S. 864 (1902)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Griffin v. Brooklyn Ball Club

New York Supreme Court, Appellate Division
73 N.Y.S. 864 (1902)

Facts

In December 1898, Michael Griffin (plaintiff) contracted with the Brooklyn Ball Club (Brooklyn) (defendant) to play baseball for Brooklyn for the 1899 season for $3,500. Brooklyn could (1) assign Griffin’s contract to another member of the league, in which case it would remain in full force, and (2) renew the contract for up to two more years at the same salary. In March 1899, Brooklyn notified Griffin that it released him to the Cleveland Baseball Company (Cleveland). However, Cleveland did not consider itself bound by Griffin’s Brooklyn contract and sought to pay him a lower salary. In response, Griffin indicated his readiness and willingness to play for Cleveland if it honored his Brooklyn contract. Soon thereafter, the St. Louis Baseball Association (St. Louis) advised Griffin that Cleveland released him to St. Louis. St. Louis also wanted to pay Griffin less than $3,500. Although Cleveland and St. Louis eventually offered to pay Griffin $3,500 for the 1899 season via side deals, Griffin’s contract with either would have been subject to the club’s right to renew his contract for two more years at less than $3,500 per year. Griffin ultimately took a job with a brewery for $20 per day. Griffin sued Brooklyn for breach of contract, seeking payment of his $3,500 salary for 1899. Brooklyn responded that (1) it assigned the contract to Cleveland and thus owed Griffin nothing, (2) Griffin breached the contract by refusing to play for Cleveland or St. Louis, and (3) Griffin failed to mitigate his damages by seeking other employment despite the other clubs’ willingness to pay him $3,500 for 1899. The trial court awarded Griffin damages of $2,266 ($3,500 minus his brewery pay). Brooklyn appealed.

Rule of Law

Issue

Holding and Reasoning (Hiscock, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 815,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 815,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 815,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership