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The Seitz decision of December 23, 1975, was a ruling by arbitrator Peter Seitz that effectively nullified professional baseball's reserve clause. Seitz ruled that Major League Baseball (MLB) pitchers Andy Messersmith and Dave McNally had completed their respective contracts with the Los Angeles Dodgers and Montreal Expos, making them free agents.

National League president William Hulbert created the reserve system in 1879 as a method of limiting player salaries and preventing expensive bidding wars for star players. It received two major challenges in court, from John Montgomery Ward in 1890 and Curt Flood in 1972, to little effect.

Background

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Reserve system

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Main article: Reserve clause

Professional baseball first adopted the reserve clause in 1879 at the behest of William Hulbert, the president of the National League (NL).[1] Under Hulbert's system, each NL team could "reserve" five players for its roster, and these players could not receive contract offers from opposing teams.[2] The number of reserved players expanded from five to 11 in 1883, 12 in 1885, 14 in 1887,[3] and by 1890, every player under active contract with an NL team was reserved by that team.[4] At that point, any player who signed with an NL team was placed under that team's control until they retired, were traded to another club, or were released outright from their contract.[5] Even in the case of retirement, should a player decide to return to baseball, he would be required to play for the team with which he last had a contract.[6] The reserve clause extended to the American League (AL) in 1903 when it signed an agreement with the NL to become the two-league system known as Major League Baseball (MLB).[7]

The NL had been struggling financially during Hulbert's tenure, and the reserve system was created as a way to keep player salaries under control by limiting the free agency market.[3] Players such as Tommy Bond, who were among the highest-paid in the NL, saw their salaries drop once they were reserved in 1880.[8] While the NL owners had adopted the reserve system as a cost-cutting measure, it was defended to the public as a means of ensuring baseball's competitive balance. Without the opportunity to reserve players, the wealthiest teams would accumulate all of the best players by outbidding smaller market teams in free agency.[9] The owners also argued that a reserve clause was necessary to justify a team's investment in its players: drafted with little experience, players took several years of development to reach the major leagues, and it would be unfair for a team not to reap the benefits.[10]

Several players attempted to circumvent the reserve clause, or to have it abolished or modified in court. In 1890, John Montgomery Ward helped to found the Players' League, which promised a three-year contract to all players, with no pay cuts following the first year.[11] The New York Giants took Ward to court when he left the team for the Players' League. While New York Supreme Court justice Morgan J. O'Brien ruled against Ward, he also critiqued the nature of the perpetual reserve clause, noting that major elements of Ward's contract, including his salary, were not addressed. Ultimately, Metropolitan Exhibition Co. v. Ward ruled that the reserve clause was "too indefinite" to be properly enforced.[12][13]

The reserve clause was brought to the United States Supreme Court in 1972 by Curt Flood. Flood, a center fielder for the St. Louis Cardinals, had been traded to the Philadelphia Phillies after the 1969 season, a trade to which he was opposed.[14] With the aid of the Major League Baseball Players Association, led by Marvin Miller,[15] Flood and his attorney Arthur Goldberg argued that the reserve system, which required Flood to play for the Phillies, was an antitrust violation.[16] In Flood v. Kuhn, the Supreme Court ruled by a 5–3 margin that federal antitrust law did not apply to the reserve system, as previous decisions in Federal Baseball Club v. National League and Toolson v. New York Yankees, Inc. had already created an antitrust exemption for the sport of baseball.[17][18] Part of the owners' arguments against Curt Flood contended that his dispute fell outside the domains of the US court system and were instead a collective bargaining issue best settled by arbitration.[19]

Catfish Hunter

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Catfish Hunter had a unique contract with the Oakland Athletics in 1974. He was to receive $50,000 in base salary and an additional $50,000 in annuity payments to an insurance company. Partway through the season, Athletics owner Charlie Finley realized that these payments would not count as a tax deduction for the team, and he refused to buy into the annuity.[20] The case was brought to MLB's arbitration panel as a clear breach of contract.[21]

Ten days prior to hearing Hunter's case, the arbitration panel had heard another breach of contract, in which the San Diego Padres had failed to reimburse Mike Corkins for travel expenses. While the Major League Baseball Players Association (MLBPA) had taken the case to arbitration to argue that Corkins's contract be terminated and he become a free agent, arbitrator Peter Seitz TKTKTK

Andy Messersmith

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Grievance

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In 1970, the collective bargaining agreement between MLB and the Players Association included a provision that, rather than disputes being settled internally between players and teams, players could file grievances before a panel of three arbitrators.[22] Miller hoped that a player engaged in a salary dispute would hold out, forcing their team to unilaterally renew their contract for a year, and then file a grievance at the end of the year arguing that their contract had expired. His plan failed to come to fruition, as players like Vida Blue and Ted Simmons ultimately acquiesced to lucrative contracts with their teams rather than holding out until arbitration.[23]

In the 1980s, Messersmith told The Sporting News that his decision to take the reserve clause to arbitration was "less of an economic issue at the time than a fight for the right to have control over your own destiny".[24]

Decision

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Aftermath

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See also

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References

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  1. ^ Thornton 2012, p. 158.
  2. ^ Abrams 1998, pp. 45–46.
  3. ^ a b Duquette 1999, p. 5.
  4. ^ Goldman 2008, p. 32.
  5. ^ Abrams 1998, p. 47.
  6. ^ Staudohar 1996, p. 34.
  7. ^ Duquette 1999, p. 8.
  8. ^ Banner 2013, p. 5.
  9. ^ Banner 2013, p. 9.
  10. ^ Banner 2013, pp. 9–10.
  11. ^ Lowenfish 2010, pp. 35–36.
  12. ^ Abrams 1998, p. 19.
  13. ^ Goldman 2008, p. 34.
  14. ^ Thornton 2012, p. 163.
  15. ^ Thornton 2012, p. 164.
  16. ^ Goldman 2008, p. 10.
  17. ^ Thornton 2012, pp. 172–173.
  18. ^ Staudohar 1996, p. 22.
  19. ^ Fallon 2016, p. 93.
  20. ^ Banner 2013, p. 222.
  21. ^ Banner 2013, pp. 222–223.
  22. ^ Banner 2013, p. 220.
  23. ^ Banner 2013, p. 221.
  24. ^ Fallon 2016, p. 94.

Works cited

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  • Abrams, Roger I. (1998). Legal Bases: Baseball and the Law. Philadelphia, PA: Temple University Press. ISBN 1-56639-599-2.
  • Banner, Stuart (2013). The Baseball Trust: A History of Baseball's Antitrust Exemption. New York, NY: Oxford University Press. ISBN 978-0-19-993029-6.
  • Duquette, Jerold J. (1999). Regulating the National Pastime: Baseball and Antitrust. Westport, CT: Praeger. ISBN 0-275-96535-X.
  • Fallon, Michael (2016). Dodgerland: Decadent Los Angeles and the 1977–78 Dodgers. Lincoln, NB: University of Nebraska Press. ISBN 978-0-803-28831-7.
  • Goldman, Robert M. (2008). One Man Out: Curt Flood versus Baseball. Lawrence, KS: University Press of Kansas. ISBN 978-0-7006-1603-9.
  • Lowenfish, Lee (2010). The Imperfect Diamond: A History of Baseball's Labor Wars. Lincoln, NB: Bison Books. ISBN 978-0-8032-3360-7.
  • Staudohar, Paul D. (1996). Playing for Dollars: Labor Relations and the Sports Business. Ithaca, NY: Cornell University Press. ISBN 0-8014-3280-4.
  • Thornton, Patrick K. (2012). Legal Decisions That Shaped Modern Baseball. Jefferson, NC: McFarland & Company, Inc. ISBN 978-0-7864-3780-1.
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