Metropolitan Base Ball Association v. Simmons
Pennsylvania [C.C.]
1 Pa. C.C. 134 (1885)
- Written by Steven Pacht, JD
Facts
The Metropolitan Base Ball Association (Metropolitan) (plaintiff) was a member, with seven other clubs, of an unincorporated association known as the American Association of Base Ball Clubs (association) (defendant). The association was formed in 1884 and was governed by a constitution. Among other things, the constitution set forth procedures for admitting new clubs, the payment of annual dues by clubs, annual salaries to officers, and annual meetings. On the day before the association’s scheduled annual meeting for the 1886 season, the association notified Metropolitan that its membership in the association had been forfeited, and the constitution was amended to replace it with a new club from Washington. Metropolitan sued, alleging that it (1) was not validly expelled pursuant to the association’s constitution, (2) did nothing to merit expulsion, and (3) would suffer irreparable harm because it would not be scheduled for games and thus could not recoup money it spent on its facilities. Metropolitan sought preliminary and permanent injunctions against its exclusion from the association and against the making of an 1886 schedule without its consent. The association responded that its constitution was meant to apply only to the 1885 season and that the seven clubs other than Metropolitan formed a new association with the Washington club (and without Metropolitan) for the 1886 season. The association asserted that despite telling Metropolitan that it was being excluded, it had invited Metropolitan to attend the annual meeting and did not form a new association until it was clear that Metropolitan would not attend. Notwithstanding the claimed formation of a new association, there was no written material documenting such action, such as meeting minutes, league rules, or the like. Finally, the association argued that it was justified in expelling Metropolitan because it was admitted on the express condition that it would play in New York City but reneged on that commitment by moving its games to Staten Island (which was not yet a part of New York City). The court granted Metropolitan’s request for a preliminary injunction and then proceeded to consider whether to grant a permanent injunction.
Rule of Law
Issue
Holding and Reasoning (Thayer, J.)
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