Major League Baseball’s Antitrust Immunity Defeats Baseball Scouts’ Class Action

Posted by : Matthew Wild | On : October 2, 2017

In Wyckoff v. Officer of the Commissioner of Baseball, No. 16-3795-cv, 2017 U.S App. LEXIS 16728 (Aug. 31, 2017), the Second Circuit affirmed dismissal of a putative antitrust class action brought by professional baseball scouts against Major League Baseball.  The scouts alleged that the Major League Baseballs teams conspired to depress competition in their labor market in violation of § 1 of the Sherman Act.  However, in 1922, the Supreme Court created antitrust immunity for the “business of baseball,” and “repeatedly reaffirmed baseball’s antitrust exemption.”  Id. at *3 (citations omitted).  Because the scouts’ claim fell squarely within baseball’s antitrust exemption, their antitrust claim failed.

This case illustrates the vitality of baseball’s antitrust exemption.  It is curious that no other sport has such an exemption.

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