Major League Baseball Immune From Minor League Antitrust Suit

June 20, 2023, 5:02 PM UTC

Three minor league teams won’t be able to bring an antitrust suit against Major League Baseball, the Second Circuit decided Tuesday, affirming the lower court’s decision that MLB is exempt from the Sherman Act.

The Staten Island Yankees, the Norwich Sea Unicorns and the Tri-City ValleyCats sued MLB in the US District Court for the Southern District of New York for eliminating its major league affiliations with the minor league teams. In doing so, the teams said MLB violated the Sherman Act.

The district court granted MLB’s motion to dismiss, finding that an antitrust exemption for MLB shields it from liability.

  • The Second Circuit concluded that precedent immunizes MLB to antitrust claims
  • The US Supreme Court decided in 1922 that exhibitions of baseball don’t implicate the antitrust act because they don’t involve interstate trade or commerce
  • Judges Barrington D. Parker, Michael H. Park, and Alison J. Nathan sat on the panel

The teams are represented by Weil, Gotshal & Manges LLP and Berg & Androphy. MLB is represented by Sullivan & Cromwell LLP.

The case is Nostalgic Partners, LLC. v. Maj. League Baseball, 2d Cir., No. 22-2859, 6/20/23.


To contact the reporter on this story: Emily Garcia at egarcia@bloombergindustry.com

To contact the editors responsible for this story: Martina Stewart at mstewart@bloombergindustry.com; Patrick L. Gregory at pgregory@bloombergindustry.com

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