## Facts

- A professional baseball catcher signed a 1913 playing contract with a Philadelphia club that allocated 75% of salary for 1913 services and 25% as consideration for his promise to accept reservation for the 1914 season.
- The 1913 contract gave the club a right to terminate on ten days’ written notice during the contract term and included a reservation clause requiring the player, if reserved, to contract with and continue in the club’s service for the next season.
- The Philadelphia club reserved the player for the 1914 season pursuant to the 1913 contract.
- In January 1914, the player signed a separate contract with a Chicago Federal League club for the 1914–1916 seasons, promising to play exclusively for that club during those seasons.
- The Chicago club sought equitable relief to prevent the player from playing for Philadelphia and to protect performance of the Federal League contract, alleging the player’s services were unique and damages would be inadequate.
- The dispute turned on whether the Philadelphia club’s 1913 reserve-based right to 1914 services had priority over the later Federal League contract.

## Issues

1. Whether the 1913 contract’s reserve clause, supported by an express salary allocation as consideration, created an enforceable obligation binding the player to the Philadelphia club for the 1914 season.
2. Whether a court of equity should enjoin the player from performing for Philadelphia and effectively enforce the later Federal League contract despite the earlier, conflicting contractual obligation.
3. Whether the asserted uniqueness of the player’s services justified equitable relief for the later-contracting club when contractual priority lay elsewhere.

## Decision

- The court held the 1913 contract’s reservation arrangement was valid and enforceable for the 1914 season.
- The court determined the Philadelphia club’s rights to the player’s 1914 services, arising from the earlier contract and supported by consideration, took precedence over the later Federal League contract to the extent it covered 1914.
- The court refused to grant the Chicago club’s requested injunctive relief restraining the player from playing for Philadelphia or otherwise giving equitable protection to the later contract that would override the earlier obligation.

## Legal Principles

- A reserve/continuation clause is enforceable when the contract provides clear, bargained-for consideration for the player’s promise to accept reservation for a subsequent season.
- Equity will not grant injunctive relief that would facilitate breach of a prior valid contract or give effect to a later agreement inconsistent with existing contractual duties.
- Even where an athlete’s services are sufficiently special that damages may be inadequate, equitable relief depends on the claimant’s superior legal and equitable right; uniqueness alone does not displace contractual priority.

## Conclusion

The court enforced the player’s earlier reserve-based obligation to the Philadelphia club for the 1914 season and denied equitable relief sought by the later-contracting Federal League club because enforcing the later agreement would conflict with a valid, consideration-supported prior contract.


Weegham v. Killefer, 215 F. 168 (W.D. Mich. 1914)