## Facts

- A professional baseball club employed Napoleon “Nap” Lajoie under a fixed-term player contract that allowed renewal up to three years.
- The contract required exclusivity: Lajoie could not play for any other club during the term without written consent.
- The contract authorized the club to seek legal or equitable relief, including an injunction, if Lajoie breached and agreed to play elsewhere.
- The contract also gave the club a unilateral right to end its obligations on ten days’ written notice, after which Lajoie would have no salary claim beyond the notice period.
- During the contract term, Lajoie arranged to play for a rival organization.
- The club alleged Lajoie was a highly skilled player and public draw whose departure would weaken the team and reduce attendance in ways not readily measurable as money damages.

## Issues

1. Whether equity may enforce an exclusive-services agreement by enjoining a professional baseball player from playing for a rival club, even though a court will not order affirmative specific performance of personal services.
2. Whether a unilateral ten-day termination clause renders the contract unenforceable in equity for lack of mutuality of remedy.

## Decision

- The Supreme Court of Pennsylvania reversed the dismissal of the equity action and granted injunctive relief.
- The court held that Lajoie’s services were sufficiently unique and of peculiar value that breach would cause irreparable injury not adequately compensable by damages.
- The court rejected the mutuality objection, holding that the club’s ten-day termination option did not bar equitable enforcement of the negative covenant while the contract remained in effect.
- The remedy was limited to a negative injunction restraining Lajoie from playing for competing clubs during the contract period, not an order compelling him to play for the club.

## Legal Principles

- Courts generally will not decree specific performance of personal service contracts, but may enforce an exclusive-services agreement by enjoining the employee from performing for others.
- A negative injunction is appropriate where the promised services are unique or of special value and the loss is not adequately remediable by damages.
- A contract is not necessarily unenforceable in equity for lack of mutuality of remedy merely because one party has a contractual option to terminate on short notice; such an option can be part of the agreed consideration and does not preclude enforcing remaining contractual rights while the agreement subsists.

## Conclusion

The court enforced the player’s exclusivity obligation through a negative injunction based on the unique value of his services and the inadequacy of damages, and it held that the employer’s short-notice termination right did not defeat equitable relief during the contract term.


Philadelphia Ball Club, Ltd. v. Lajoie, 202 Pa. 210, 51 A. 973 (Pa. 1902)