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Judge Carter: MLB’s Antitrust Exemption “Shields” MLB from Minor League Baseball Teams’ Sherman Act Suit

By Meghan Newcomer on October 28, 2022
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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).

Judge Carter found that while Plaintiffs had established antitrust standing and had adequately pleaded an antitrust violation, MLB’s antitrust exemption for the “business of baseball” barred the suit. Judge Carter considered both the Plaintiffs’ argument that the Supreme Court was poised to knock out the exception, and the statement of interest filed by the United States “urging the Court to scrutinize baseball’s exemption narrowly,” but concluded that “until the Supreme Court or Congress takes action, the exemption survives; it shields MLB from Plaintiffs’ lawsuit.”

Citing the Second Circuit’s 2017 opinion in Wyckoff v. Office of Commissioner of Baseball, 705 F. App’x 26, 29 (2d Cir. 2017), Judge Carter found that:

Even analyzing the exemption narrowly, the exemption is wide enough to encompass the claims here. As Plaintiffs concede, Wycoff’s interpretation of baseball’s exemption forecloses their case since minor league affiliations are central to the business of baseball. Baseball’s antitrust exemption will not brook this lawsuit; the case is dismissed.

Photo of Meghan Newcomer Meghan Newcomer

Meghan Newcomer is an accomplished litigator who focuses her practice on complex civil litigation, white-collar criminal defense, and government and internal investigations. Meghan competently navigates clients through complex commercial disputes in both state and federal court and in arbitration proceedings. She skillfully handles…

Meghan Newcomer is an accomplished litigator who focuses her practice on complex civil litigation, white-collar criminal defense, and government and internal investigations. Meghan competently navigates clients through complex commercial disputes in both state and federal court and in arbitration proceedings. She skillfully handles all phases of litigation, from managing broad discovery to drafting dispositive motions, always focused on achieving the best outcome for her clients. On the criminal side, Meghan has substantial trial experience defending individuals in white-collar criminal matters and has participated in multiple criminal trials in federal court. Meghan also has experience representing clients in high-stakes investigations by the US Department of Justice and the New York State Attorney General’s Office.

Read more about Meghan NewcomerEmail
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  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    SDNY Blog
  • Organization:
    Steptoe LLP
  • Article: View Original Source

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