## Facts

- The Major League Baseball collective bargaining agreement expired on December 31, 1993.
- After negotiations failed, players struck, leading to cancellation of the remainder of the 1994 season (including the World Series) and part of the 1995 season.
- Putative classes of plaintiffs included (1) fans claiming injury from the loss of games and (2) nearby businesses (e.g., restaurants near stadiums) claiming lost revenue from reduced game-day traffic.
- Defendants included Major League Baseball, the leagues, the Commissioner, and the major league clubs (the Owners).
- The National Labor Relations Board pursued an unfair labor practice case against the Owners, and a federal court issued a § 10(j) injunction restoring terms of the expired agreement pending specified labor-law developments.

## Issues

1. Whether professional baseball’s judicially recognized antitrust exemption covers the challenged conduct connected to cancellation of games during the labor dispute, or is limited to reserve-clause/player-contract matters.
2. Whether fans and stadium-area businesses alleged antitrust injury and sufficiently direct harm to have antitrust standing.
3. Whether federal labor law (including the nonstatutory labor exemption and the NLRB’s role) bars or displaces the private antitrust claims arising from the labor dispute.

## Decision

- The court granted defendants’ motion to dismiss and denied plaintiffs’ motion for summary judgment.
- The court held that MLB’s antitrust exemption applied to the challenged conduct and foreclosed the antitrust claims.
- Independently, the court held that both fans and nearby businesses lacked antitrust standing because their alleged injuries were indirect and not the type the antitrust laws redress.
- The court further treated the claims as arising from a collective-bargaining conflict governed by federal labor law, supporting dismissal under labor-law doctrines, including the nonstatutory labor exemption.

## Legal Principles

- Under controlling Supreme Court precedent, professional baseball enjoys a judicially recognized exemption from federal antitrust law for conduct within the “business of baseball,” and any major change is for Congress rather than lower courts.
- Antitrust standing requires antitrust injury and sufficient directness; injuries that are derivative of a labor dispute’s effects on others, or are incidental to alleged restraints, are generally too remote.
- Businesses claiming lost profits from reduced patronage due to cancelled events typically lack antitrust standing when they are not participants in the restrained market and their losses depend on intervening consumer choices.
- When challenged conduct is part of a collective-bargaining process, the nonstatutory labor exemption and the labor-law remedial scheme (including NLRB proceedings) can preclude private antitrust remedies.

## Conclusion

The court dismissed fans’ and nearby businesses’ antitrust claims stemming from strike-related game cancellations, ruling that the claims were barred by baseball’s antitrust exemption, failed for lack of antitrust standing, and conflicted with the labor-law framework governing the underlying dispute.


McCoy v. Major League Baseball, 911 F. Supp. 454 (W.D. Wash. 1995)