Metropolitan Exhibition Company v. Ward
New York Supreme Court
9 N.Y.S. 779 (1890)
- Written by Steven Pacht, JD
Facts
On April 23, 1889, the New York Base-Ball Club (club) contracted with John Montgomery Ward (defendant) to play for the club through October 1889. Consistent with league practice, the contract allowed the club to reserve Ward for 1890. The club could terminate the contract at any time if Ward violated it or with 10 days’ notice for any reason, but the contract gave Ward no right to early termination. The parties also signed a supplemental contract stating that Ward would not be “held” for less than $3,000. When the club and Ward did not agree on a contract for 1890, the Metropolitan Exhibition Company (Metropolitan) (plaintiff)—which organized the club’s exhibitions, or games—sought preliminary and permanent injunctions preventing Ward from playing baseball for anyone else in 1890. Metropolitan argued that the reserve clause clearly and unambiguously meant it could hold Ward for future use and constituted a definite contract requiring Ward to play for the club in 1890. Ward countered that the reserve clause’s history meant it barred him only from playing for other league clubs but allowed him to play in other leagues and that an injunction to enforce a personal-services contract would be improper.
Rule of Law
Issue
Holding and Reasoning (O’Brien, J.)
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