On Wednesday, Judge Carter granted Major League Baseball’s Motion to Dismiss the Complaint of four Minor League Baseball teams alleging that MLB violated the Sherman Act by orchestrating an agreement among its clubs to eliminate 40 minor league teams from affiliation with major league clubs. As discussed in a previous post, Plaintiffs argued the Supreme Court had signaled its willingness to reconsider MLB’s exemption from antitrust scrutiny in NCAA v. Alston, 141 S. Ct. 2141 (2021).
Continue Reading Judge Carter: MLB’s Antitrust Exemption “Shields” MLB from Minor League Baseball Teams’ Sherman Act Suit

In a complaint filed today, four minor league baseball teams sued Major League Baseball for violating the Sherman Act by allegedly orchestrating an agreement among its clubs to eliminate 40 minor league teams (out of 160) from being affiliated with major league clubs.

The Staten Island Yankees, Tri-City Valley Cats, Salem-Keizer Volcanoes and Norwich Sea Unicorns allege that MLB “collectively decided to artificially reduce the number” of affiliated minor league teams to cut expenses, instead of allowing the free market to determine which minor league teams will survive and prosper.  The Plaintiffs allege they brought the suit given the Supreme Court’s recent signaling in NCAA v. Alston, 141 S. Ct. 2141 (2021) of its willingness to reconsider MLB’s exemption from antitrust scrutiny:
Continue Reading Minor League Baseball Teams Sue MLB for Antitrust Violations

Today, Judge Sullivan remanded to New York state court a case against MLB brought by a former Milwaukee Brewers and Cincinnati Reds player Neiman Nix.  The complaint alleged that MLB investigators spread misinformation about Nix’s player training academy and “sports science testing facility” in Florida, and included claims for defamation, tortious interference, and violation of the Computer Fraud and Abuse Act.

Judge Sullivan dismissed the sole federal claim under the CFAA at the plaintiff’s behest, despite the defendants’ argument that plaintiffs’ position was solely intended to defeat federal jurisdiction.  Judge Sullivan found that while forum manipulation was frowned upon, it did not require the court to exercise its supplemental jurisdiction after all federal claims had been dismissed:
Continue Reading Judge Sullivan: Plaintiff Can Voluntarily Drop Federal Claim to Get Back in State Court