Metropolitan Base Ball Association v. Simmons

1 Pa. C.C. 134 (1885)

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

Metropolitan Base Ball Association v. Simmons

Pennsylvania [C.C.]
1 Pa. C.C. 134 (1885)

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.)

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 816,000 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 816,000 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 816,000 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