## Facts

- Major League Baseball’s reserve system changed in 1976 after arbitration recognized that players who played out an “option year” could become free agents absent a new contract.
- To protect the new free-agency system, the Commissioner issued multiple anti-tampering directives to clubs, including warnings against indirect communications through public media statements and notice that discipline could include suspensions and loss of draft picks.
- The Commissioner found that a Braves employee had tampered with free agent Gary Matthews and imposed discipline on the club, including a $10,000 fine and forfeiture of an amateur draft choice.
- Ted Turner, a Braves executive, publicly told the San Francisco Giants’ owner—while media were present—that he would pay whatever was necessary to sign Matthews; the Commissioner suspended Turner for one year.
- The Braves and Turner sued the Commissioner in federal district court seeking to enjoin enforcement of the sanctions, arguing the Commissioner exceeded his contractual authority under the Major League Agreement (MLA).
- After a bench trial (following cross-motions for summary judgment), the district court resolved the merits by construing the MLA as a contract governing the Commissioner’s authority.

## Issues

1. Whether the MLA’s “best interests of baseball” provision authorized the Commissioner to issue anti-tampering directives regulating contacts and communications concerning free agents.
2. Whether the MLA authorized the Commissioner to impose the specific sanctions challenged, including Turner’s one-year suspension and forfeiture of a club draft pick.
3. Whether, and to what extent, a club’s contractual commitments under the MLA limited judicial review of the Commissioner’s disciplinary decisions.

## Decision

- The court denied injunctive relief and upheld the Commissioner’s authority to issue anti-tampering directives as an exercise of his “best interests of baseball” power under the MLA.
- The court upheld Turner’s one-year suspension as within the Commissioner’s disciplinary authority and not arbitrary in light of the prior directives and Turner’s public conduct.
- The court treated review as limited to determining whether the Commissioner acted within contractually delegated authority and declined to substitute its judgment on the appropriateness of discipline once authorized by the MLA.

## Legal Principles

- League governance agreements like the MLA are construed as contracts defining the commissioner’s authority and the permissible scope of internal discipline.
- A commissioner’s contractual power to act in the “best interests of baseball” may include substantive authority to issue directives addressing new conditions affecting competitive integrity and orderly league operation.
- Courts may review whether a commissioner exceeded contractual authority or acted outside contractual procedures, but will generally defer to disciplinary judgments that fall within the contract’s broad grant of power and are not arbitrary or in bad faith.
- Disciplinary authority may extend beyond rigidly enumerated penalties when the agreement’s structure and purpose support measures reasonably related to deterring conduct harmful to the sport.

## Conclusion

The district court, applying contract-based and deferential review, sustained the Commissioner’s use of the MLA’s “best interests of baseball” authority to deter free-agent tampering and upheld the principal discipline imposed, refusing to enjoin enforcement of the Commissioner’s actions.


Atlanta Nat’l League Baseball Club, Inc. v. Kuhn, 432 F. Supp. 1213 (N.D. Ga. 1977)