McCoy v. Major League Baseball

911 F. Supp. 454 (1995)

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McCoy v. Major League Baseball

United States District Court for the Western District of Washington
911 F. Supp. 454 (1995)

Facts

The collective-bargaining agreement (CBA) between the owners of the 28 Major League Baseball clubs (owners) and the Major League Baseball Players Association expired on December 31, 1993, leading the players to go on strike during the 1994 season. The strike resulted in the cancellation of some of the 1994 regular season as well as the 1994 World Series and some of the 1995 season. The National Labor Relations Board (NLRB) ultimately brought suit in federal court, charging the owners with committing an unfair labor practice. The district court issued a preliminary injunction that reinstated the prior CBA until the parties reached a new agreement or until the NLRB or the court took further action. Martin B. Friend and John McCoy (fans) (plaintiffs) brought putative class actions against the owners, the American League, the National League, the commissioner of baseball, and Major League Baseball (collectively, MLB) (defendants) on behalf of baseball fans. In addition, Trattoria Mitchelli—a restaurant located near the home stadium for the Seattle Mariners—and other businesses (businesses) (plaintiffs), brought a putative class action against MLB on behalf of businesses that operated near MLB home stadiums that allegedly suffered due to the canceled games. The fans and businesses alleged that MLB violated federal antitrust law. MLB moved to dismiss the claims on the basis of MLB’s antitrust exemption and the lack of antitrust standing by both the fans and the businesses. The fans and businesses countered by moving for partial summary judgment on those issues, arguing that (1) MLB’s antitrust exemption applied only to MLB’s reserve-clause system and not to MLB’s entire business, (2) the fans had antitrust standing because they were MLB consumers, and (3) the businesses had antitrust standing because they were injured by the cancellation of games due to MLB’s actions.

Rule of Law

Issue

Holding and Reasoning (Dimmick, C.J.)

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