## Facts

- John O’Connor was hired under a written contract to manage the St. Louis American League club.
- The contract contained inconsistent language: one clause indicated employment for the 1910 and 1911 seasons, while another referred to the 1910 season only.
- After the 1910 season, controversy arose from a game in which Cleveland’s Napoleon Lajoie was competing with Detroit’s Ty Cobb for the batting title.
- Evidence suggested O’Connor may have instructed a fielder to position unusually to increase Lajoie’s chances of getting hits; the incident became public.
- The American League president investigated and communicated that O’Connor should not remain manager.
- The club terminated O’Connor and refused to retain him for 1911.
- O’Connor sued for breach, claiming a two-season contract and termination without good cause.
- A jury found for O’Connor and awarded damages; the club appealed.

## Issues

1. When a written employment contract contains conflicting clauses about its term, may the court admit extrinsic evidence to determine the parties’ intent regarding duration?
2. If the contract covered 1911, did the evidence establish good cause for termination as a matter of law based on alleged fraud or conduct injuring (or tending to injure) the club’s business and reputation?

## Decision

- The appellate court affirmed the judgment for O’Connor.
- The contract was ambiguous as to duration, and the trial court properly admitted extrinsic evidence to aid interpretation.
- The evidence permitted the jury to find the agreement covered both the 1910 and 1911 seasons.
- The club’s evidence did not conclusively prove fraud or sufficiently injurious misconduct to justify termination as a matter of law.
- Whether O’Connor was discharged for good cause was properly submitted to the jury, and the verdict was supported by substantial evidence.

## Legal Principles

- When a contract is facially ambiguous due to conflicting provisions, extrinsic evidence (including negotiations, surrounding circumstances, and the parties’ understanding) is admissible to clarify intent; the parol evidence rule does not bar explanatory evidence used to resolve ambiguity.
- An employer asserting discharge-for-cause based on fraud or serious misconduct must prove conduct amounting to fraud or conduct that injures or clearly tends to injure the employer’s business; suspicion, adverse publicity, or equivocal proof does not compel judgment against an employee as a matter of law.
- Appellate courts generally defer to a jury’s resolution of disputed facts and inferences when supported by substantial evidence.

## Conclusion

The court upheld a jury verdict for a discharged baseball manager, holding that conflicting contract provisions created an ambiguity permitting extrinsic evidence to show a two-season term, and that the club failed to prove discharge-for-cause as a matter of law based on alleged game-manipulation misconduct.


O’Connor v. St. Louis American League Baseball Co., 181 S.W. 1167 (Mo. Ct. App. 1916)