## Facts

- Tampa Bay investors sought to buy the San Francisco Giants and relocate the franchise to Tampa Bay, Florida.
- Major League Baseball club owners did not approve the proposed sale/relocation; the Giants’ owner later agreed to sell to San Francisco investors, keeping the team in San Francisco.
- Florida’s Attorney General opened an antitrust investigation into a possible combination or conspiracy restraining trade in connection with the franchise sale/relocation.
- The Attorney General issued civil investigative demands (CIDs) under Florida’s antitrust investigation statute to the National League and its president, seeking information about potential federal and state antitrust violations.
- The National League moved to set aside the CIDs, arguing that professional baseball is exempt from antitrust law under controlling federal precedent.

## Issues

1. Whether the federal antitrust exemption for professional baseball categorically exempts decisions involving the sale and location of franchises from federal and Florida antitrust law.
2. Whether that claimed exemption barred the Florida Attorney General from using CIDs to investigate the failed Giants sale/relocation.

## Decision

- The Florida Supreme Court answered the certified question “no” and quashed the decision that had set aside the CIDs.
- The court held the baseball antitrust exemption is narrow and extends only to the reserve system, not to all business decisions of Major League Baseball.
- Because franchise sale and relocation decisions were not clearly within the exemption, the Attorney General was not precluded from investigating and could proceed with the CIDs.
- The court did not decide whether any antitrust violation occurred; it addressed only whether the investigation was categorically barred.

## Legal Principles

- Federal baseball antitrust precedent creates a limited exemption tied to the reserve system; it is not a blanket immunity for professional baseball’s franchise ownership, sale, or location decisions.
- State courts applying federal antitrust precedent must follow controlling holdings but need not extend an anomalous federal doctrine beyond the issues actually decided.
- Florida antitrust law, though patterned on federal antitrust law, should not expand a narrowly construed federal exemption absent clear direction from Congress or the U.S. Supreme Court.
- The existence of a disputed or limited antitrust exemption does not, by itself, foreclose a state attorney general’s investigatory authority where the subject matter is outside the exemption’s established scope.

## Conclusion

The court held that baseball’s antitrust exemption is confined to the reserve system and does not automatically shield franchise sale and relocation decisions, allowing Florida’s Attorney General to pursue an antitrust investigation through civil investigative demands.


Butterworth v. Nat'l League of Prof'l Baseball Clubs, 644 So. 2d 1021 (Fla. 1994)