State v. Milwaukee Braves

144 N.W.2d 1 (1966)

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State v. Milwaukee Braves

Wisconsin Supreme Court
144 N.W.2d 1 (1966)

Facts

The Milwaukee Braves, Inc. (Braves) (defendant) played in the National League (NL) of Major League Baseball (MLB). In October 1964, the Braves’ board of directors decided to move the Braves to Atlanta. The NL approved the move but required the Braves to fulfill the last year of its Milwaukee stadium lease by delaying the move until the 1966 season. In August 1965, the State of Wisconsin (plaintiff) sued the Braves, the NL, and the owners of the nine other NL clubs (defendants), alleging they violated Wisconsin’s antitrust law by combining and conspiring among themselves to monopolize major-league baseball in Wisconsin. After a trial, the circuit court ruled for Wisconsin, finding, among other things, that the NL and its clubs violated Wisconsin’s antitrust law and that it was feasible to expand the NL to add a new Milwaukee team. Accordingly, the circuit court issued an injunction prohibiting the NL and its club owners from rejecting an application by a suitable entity, like Milwaukee County or the Milwaukee Brewers Baseball Club, Inc.—both of which already unsuccessfully applied to both the NL and the American League for membership—from joining the NL with a home in Milwaukee. The injunction also required the NL and its club owners to facilitate a new club in Milwaukee by 1967 and barred the Braves from playing anywhere other than Milwaukee until a new Milwaukee franchise was granted. The NL and its club owners appealed, arguing, among other things, that major-league baseball involved interstate commerce and the enforcement of Wisconsin’s antitrust policy with respect to major-league baseball would directly affect the NL and its club owners’ business beyond Wisconsin and thus would violate the Commerce Clause and the Supremacy Clause of the United States Constitution.

Rule of Law

Issue

Holding and Reasoning (Fairchild, J.)

Dissent (Heffernan, J.)

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