O'Connor v. St. Louis American League Baseball Co.

John O’Connor (plaintiff) contracted with the St. Louis American League Baseball Co. (St. Louis) (defendant) to serve as its manager. The contract’s first clause stated that it was for the 1910 and 1911 seasons, but its second clause stated that it was for only the 1910 season. At the end of the 1910 season, O’Connor allegedly instructed the team’s third baseman, Red Corriden, to position himself so as to make it easier for an opposing player, Cleveland’s Napoleon Lajoie, to get hits that would raise Lajoie’s batting average because O’Connor wanted Lajoie to finish the season with the league’s highest batting average ahead of Detroit’s Ty Cobb. Soon thereafter, Ban Johnson, the president of the American League, summoned O’Connor and others, at Johnson’s expense, to discuss whether O’Connor tried to help Lajoie. Johnson ultimately decided that O’Connor should not remain St. Louis’s manager, leading St. Louis to write O’Connor that it was terminating O’Connor’s contract for 1911. O’Connor sued for breach of contract. St. Louis responded that, among other things, the contract’s second clause controlled and thus it contracted with O’Connor only for the 1910 season. St. Louis further argued that to the extent the contract was ambiguous as to its term, the court should interpret it without considering testimony about the parties’ intentions or negotiations. Finally, St Louis argued that even if the contract covered 1911, it had good cause to terminate O’Connor because his alleged actions to help Lajoie either (1) were a fraud against St. Louis or (2) injured, or had a tendency to injure, St. Louis’s business even if not fraudulent. However, although St. Louis presented evidence regarding Corriden’s positioning and the results of Lajoie’s at-bats, it did not submit substantial evidence that O’Connor favored Lajoie over Cobb or acted to help Lajoie. The jury ruled for O’Connor. St. Louis appealed.