Major League Baseball v. Morsani

In 1984, the majority owners of the Minnesota Twins (Twins), a Major League Baseball (MLB) (defendant) franchise, agreed to sell their majority interest to Frank Morsani (plaintiff) provided Morsani first purchased the minority interest currently owned by a third-party. Morsani purchased the minority interest; however, the majority interest was subsequently sold to another buyer. MLB then demanded that Morsani assign his minority interest in the Twins to the new majority owner at a steep discount. In exchange, and to prevent Morsani from suing over the Twins transaction, MLB promised Morsani that he would be first-in-line to obtain ownership of an MLB franchise in time for the 1993 season. Morsani agreed and assigned his minority interest to the Twins’ new owner. Subsequently, Morsani made two more unsuccessful attempts to purchase an MLB franchise, both of which MLB ultimately granted to third-party buyers. In 1992, Morsani sued MLB, arguing that MLB tortiously interfered with Morsani’s purchase of the Twins in 1984. MLB moved to dismiss, arguing that Morsani’s claim was barred by the applicable four-year statute of limitations. Morsani countered, arguing that equitable estoppel barred MLB from raising a statute-of-limitations defense because Morsani delayed filing his claim in reliance on MLB’s promises. The trial court dismissed Morsani’s claim, holding that, under Florida’s tolling statute, equitable estoppel could not be used to toll the statute of limitations. On appeal, the district court reversed, holding that equitable estoppel and tolling were distinct doctrines and, therefore, the tolling statute had no impact on the applicability of equitable estoppel. The district court then certified a question to the Florida Supreme Court about whether Florida’s tolling statute prohibited the application of equitable estoppel to an untimely claim.