Major League Baseball v. Butterworth
United States District Court for the Northern District of Florida
181 F. Supp. 2d 1316 (2001)
- Written by Steven Pacht, JD
Facts
In November 2001, Major League Baseball (MLB) (plaintiff) decided to contract from 30 clubs to 28 clubs. Florida’s attorney general, Robert Butterworth (plaintiff), sought to investigate whether MLB’s action violated federal and Florida antitrust law by issuing civil investigative demands (CIDs) to MLB and the two Florida-based MLB clubs (plaintiffs). MLB and the Florida-based clubs filed suit, seeking a declaratory judgment that MLB’s contraction decision was immune from antitrust law pursuant to the United States Supreme Court’s rulings in Federal Baseball Club of Baltimore, Inc. v. National League of Professional Baseball Clubs, Toolson v. New York Yankees, Inc., and Flood v. Kuhn. MLB and the Florida-based clubs also sought an injunction against the CIDs. MLB further argued that the 1998 Curt Flood Act (Flood Act) reflected Congress’s endorsement of MLB’s antitrust immunity. Butterworth responded that MLB’s antitrust immunity embraced only MLB’s player-reserve system because the alleged original rationale for MLB’s broader immunity—that MLB did not engage in interstate commerce—no longer was valid. In addition, Butterworth argued that even if MLB’s immunity shielded all of the business of baseball, MLB’s contraction decision was not part of the business of baseball.
Rule of Law
Issue
Holding and Reasoning (Hinkle J.)
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