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.