## Facts

- George Earl Toolson was a professional pitcher in the New York Yankees’ minor-league farm system, pitching for the Newark Bears.
- Professional baseball player contracts included a reserve clause that allowed clubs to retain a player’s rights after contract expiration, limiting players’ ability to negotiate with other teams.
- After the Newark franchise dissolved, the Yankees reassigned Toolson to a lower-level minor-league team; Toolson refused to report.
- Toolson sued major league entities alleging the reserve system and related practices restrained trade and violated the Sherman Antitrust Act.
- The federal district court ruled against Toolson, and the Ninth Circuit affirmed.
- The Supreme Court granted certiorari and consolidated the case with two similar player challenges (Kowalski and Corbett).

## Issues

1. Whether the business of professional baseball, including the reserve system restricting player movement, is subject to the Sherman Act.
2. Whether the Court should overrule Federal Baseball Club of Balt., Inc. v. Nat’l League of Pro. Baseball Clubs and apply antitrust law to professional baseball.

## Decision

- The Court affirmed the judgments against the players in a per curiam decision.
- The Court relied on Federal Baseball as controlling authority, to the extent it determined Congress did not intend the federal antitrust laws to cover professional baseball.
- The Court declined to reexamine the underlying commerce and antitrust questions.
- The Court reasoned that Congress had considered the matter but had not enacted legislation bringing baseball within the antitrust laws, and that any change should come through legislation rather than judicial overruling with retrospective effect.
- Justice Burton, joined by Justice Reed, dissented, arguing modern organized baseball operated in interstate commerce and lacked any express statutory antitrust exemption.

## Legal Principles

- Professional baseball’s business, including the reserve system, is outside the scope of federal antitrust laws as a matter of Supreme Court precedent reaffirming Federal Baseball.
- Congressional inaction in the face of an established judicial interpretation may be treated as a reason to leave that interpretation undisturbed.
- If application of federal antitrust law to professional baseball is warranted, the Court indicated it should occur through prospective legislative action rather than retroactive judicial change.

## Conclusion

The Supreme Court preserved baseball’s antitrust exemption by reaffirming Federal Baseball and treating Congress’s failure to legislate as a reason to leave professional baseball outside the Sherman Act.


Toolson v. N.Y. Yankees, Inc., 346 U.S. 356 (1953)