## Facts

- Vincent M. Piazza, Vincent N. Tirendi, and their corporation, PT Baseball, Inc. (PTB), sought to acquire the San Francisco Giants and relocate the franchise to the Tampa Bay area.
- On August 6, 1992, the investor group executed a letter of intent with the Giants’ owner to purchase the team for $115 million.
- On August 18, 1992, plaintiffs and additional investors executed a memorandum of understanding to form a limited partnership to acquire the Giants.
- On August 26, 1992, PTB entered into a limited partnership agreement creating the Tampa Bay Baseball Club, Ltd., under which PTB would contribute $27 million.
- Plaintiffs alleged they had arrangements connected to a stadium plan in St. Petersburg, Florida, to support relocation.
- Plaintiffs alleged Major League Baseball (MLB) and related league entities and officials interfered with the proposed purchase and relocation.
- Plaintiffs alleged defendants defamed them by falsely associating them with criminal activity, causing financial harm and contributing to the rejection of the relocation proposal.
- Plaintiffs asserted federal antitrust claims, constitutional claims (including under 42 U.S.C. § 1983), and related state-law claims.
- Defendants moved to dismiss, arguing lack of subject-matter jurisdiction, failure to state federal claims, and that baseball is exempt from federal antitrust liability under Supreme Court precedent.

## Issues

1. Whether MLB’s judicially recognized antitrust exemption bars federal antitrust claims arising from alleged obstruction of a franchise sale and relocation.
2. Whether plaintiffs sufficiently alleged “state action” or action “under color of state law” to support a claim under 42 U.S.C. § 1983.
3. Whether plaintiffs could maintain direct causes of action under the Constitution against MLB apart from § 1983.
4. Whether the pleaded federal claims were sufficient at the motion-to-dismiss stage to support federal jurisdiction and proceed, with state-law claims remaining in the case.

## Decision

- The court granted the motion to dismiss as to plaintiffs’ direct constitutional claims.
- The court denied the motion to dismiss the federal antitrust claims, holding MLB’s antitrust exemption did not apply to the alleged franchise sale/relocation conduct.
- The court denied the motion to dismiss the § 1983 claim, holding the complaint sufficiently alleged conduct under color of state law at the pleading stage.
- The court denied dismissal of related state-law claims, retaining them because federal claims remained pending.

## Legal Principles

- MLB’s antitrust exemption is narrowly construed and limited to the player “reserve system”; it does not categorically immunize franchise sales, ownership decisions, territorial rules, or relocation conduct from federal antitrust scrutiny.
- At the pleading stage, antitrust claims may proceed where plaintiffs plausibly allege conduct restraining trade and affecting interstate commerce, absent a controlling immunity applicable to the challenged conduct.
- A private entity may be treated as acting under color of state law for § 1983 purposes when the complaint plausibly alleges conspiracy or joint participation with governmental actors.
- Direct claims for constitutional violations are generally not viable against non-governmental defendants absent an applicable statutory vehicle and sufficient governmental action; § 1983 is the usual mechanism for damages claims premised on constitutional violations by state actors.

## Conclusion

The court allowed plaintiffs to proceed on antitrust and § 1983 theories challenging MLB’s alleged interference with a franchise purchase and relocation, ruling that baseball’s antitrust exemption did not extend beyond the reserve system, while dismissing plaintiffs’ freestanding constitutional claims.


Piazza v. Major League Baseball, 831 F. Supp. 420 (E.D. Pa. 1993)