## Facts

- Chicago National League Ball Club, Inc. (the Cubs) was a Major League Baseball club in the National League (NL) and had played in the NL’s Eastern Division since 1968.
- NL clubs sought divisional realignment that would have moved the Cubs from the Eastern Division to the Western Division.
- The NL Constitution included § 9.4, which prevented moving a club to a different division without that club’s consent.
- The NL clubs voted 10–2 in favor of realignment, but the Cubs voted against it; under § 9.4, the Cubs’ lack of consent meant the proposal failed.
- Commissioner Francis T. Vincent later issued an order implementing the realignment anyway, including transferring the Cubs to the Western Division.
- Vincent relied on Article I of the Major League Agreement (MLA), which authorized the commissioner to investigate conduct not in the “best interests of baseball” and to impose remedial, preventive, or punitive action.
- The Cubs sued in federal court seeking declaratory relief and preliminary and permanent injunctions to stop the forced realignment.
- The Cubs argued that the commissioner exceeded his Article I authority and that MLA Article VII barred the commissioner from deciding disputes whose resolution was otherwise governed by the NL Constitution.

## Issues

1. Whether the commissioner’s “best interests of baseball” authority under MLA Article I permitted him to impose NL divisional realignment by moving the Cubs without their consent, despite NL Constitution § 9.4.
2. Whether MLA Article VII restricted the commissioner from resolving (or re-deciding) a matter already addressed by the NL Constitution’s governance provisions.

## Decision

- The court granted preliminary injunctive relief for the Cubs.
- The court concluded the commissioner lacked contractual authority under the MLA to override NL Constitution § 9.4 and move the Cubs without their consent.
- The commissioner was enjoined from enforcing the realignment order against the Cubs.

## Legal Principles

- The commissioner’s “best interests of baseball” power is contractual and is limited by the terms of the governing league agreements.
- A broad, general management clause does not displace a specific contractual protection (such as a consent requirement) absent clear contractual language authorizing that result.
- Where a league constitution directly addresses a governance question, the commissioner may not use general “best interests” language to reach a contrary outcome.

## Conclusion

The court held that Commissioner Vincent could not use the MLA’s “best interests of baseball” authority to force the Cubs’ transfer from the NL East to the NL West because the NL Constitution expressly required the Cubs’ consent, and the MLA did not authorize the commissioner to override that requirement; the court therefore granted a preliminary injunction preventing enforcement of the realignment as to the Cubs.


Chicago National Ball Club, Inc. v. Vincent, No. 92 C 4398 (1992)