## Facts

- Metropolitan Exhibition Company owned and operated the New York Base-Ball Club.
- John Montgomery Ward played for the club under a written contract dated April 23, 1889, covering the 1889 season through October 1889.
- The 1889 contract included a “reserve” provision stating Ward could be reserved for the 1890 season.
- The club retained broad termination power, including termination for breach or on 10 days’ notice for any reason; Ward had no comparable right to terminate early.
- The parties executed a supplemental writing stating Ward would not be “held” for the 1890 season for less than $3,000.
- After the 1889 season, the parties did not reach a separate agreement for Ward’s 1890 employment; Ward intended to play in a rival league.
- Metropolitan sought preliminary and permanent injunctions to prevent Ward from playing for any other club during the 1890 season, effectively enforcing the alleged continuing obligation to provide personal services.

## Issues

1. Whether the 1889 contract’s reserve provision and the $3,000 supplemental writing formed a definite, enforceable contract requiring Ward to play for the club in 1890.
2. Whether equity may enjoin a professional athlete from playing for others where the injunction would indirectly compel personal services for the plaintiff.
3. Whether the contract’s termination terms and remedies were sufficiently mutual to justify injunctive enforcement.

## Decision

- The court denied the requested injunction.
- The court held the writings did not create a definite, enforceable contract obligating Ward to play for the club in 1890.
- The court further concluded that, even if some obligation were assumed, equitable relief was improper because the arrangement lacked mutuality and would operate as an indirect compulsion of personal services.

## Legal Principles

- A reserve clause does not, by itself, create a binding contract for a future season absent clear mutual assent to essential terms for that season.
- Equity generally will not enforce personal-service arrangements by injunction where the effect is to coerce continued service or bar a person from pursuing their occupation without a clear and fair contractual basis.
- Injunctive enforcement is disfavored where the employer retains broad power to terminate while the employee lacks comparable rights, undermining mutuality of obligation and remedy.

## Conclusion

The court refused to restrain Ward from playing for other clubs because the documents did not constitute a complete 1890 employment contract and because the one-sided termination structure made injunctive enforcement of the claimed personal-service obligation inequitable.


Metropolitan Exhibition Co. v. Ward, 9 N.Y.S. 779 (N.Y. Sup. Ct. 1890)