## Facts

- Eight professional clubs formed an unincorporated league, the American Association of Base Ball Clubs, governed by a written constitution addressing dues, officers, meetings, admissions, and scheduling.
- Metropolitan Base Ball Association became a member club and invested in players and facilities in reliance on participation in league play and scheduled games.
- Other clubs asserted Metropolitan had been admitted on an understanding that it would play home games in New York City; Metropolitan later played in Staten Island.
- On the eve of the annual meeting to organize the next season and adopt a schedule, the league notified Metropolitan that its membership was “forfeited” and amended its constitution to substitute a Washington club.
- Metropolitan alleged it was excluded without any constitutionally authorized expulsion process and that exclusion from the season schedule would cause irreparable business harm.
- The league contended the existing constitution applied only to a prior season and that the other clubs had formed a new association for the upcoming season, thereby leaving Metropolitan out without expelling it.
- Metropolitan sought injunctive relief to prevent exclusion and to prevent adoption of a schedule that omitted Metropolitan; a preliminary injunction issued and the court then considered permanent relief.

## Issues

1. Whether the league could avoid obligations under its constitution by asserting it had formed a “new association” for the next season without showing formal creation of a separate entity.
2. Whether Metropolitan was lawfully expelled or had forfeited membership under the league constitution, and whether equity could restrain noncompliant exclusion.
3. Whether Metropolitan’s change of playing location supplied sufficient grounds to terminate membership without following constitutional procedures.

## Decision

- The court treated the league as a continuing unincorporated association operating under its existing constitution, rejecting the “new association” characterization.
- The court found Metropolitan had not been validly removed under the constitution’s requirements for termination of membership.
- The court made the preliminary injunction permanent, enjoining the league from excluding Metropolitan and from adopting or implementing a schedule that omitted Metropolitan for the upcoming season.

## Legal Principles

- A voluntary unincorporated association with a written constitution is bound to act according to that constitution in dealing with membership rights.
- A majority of members may not circumvent agreed expulsion or discipline procedures by declaring a “forfeiture” or by relabeling the organization without substantiated formation of a distinct association.
- Even where asserted “cause” exists for discipline, an association must follow its internal procedures before depriving a member of rights conferred by the constitution.
- Injunctive relief is appropriate where exclusion from a time-limited competitive schedule would cause irreparable harm and damages after the fact would be inadequate.

## Conclusion

The court enforced the league’s constitution as binding on its member clubs and permanently enjoined the league from excluding Metropolitan or finalizing a season schedule without it, because the league neither proved it had formed a separate new association nor complied with constitutional procedures for terminating membership.


Metropolitan Base Ball Ass’n v. Simmons, 1 Pa. C.C. 134 (Pa. Ct. Com. Pl. 1885)