How Organized Baseball Achieved a Judicial Exemption From Federal Antitrust Laws, the Individuals and Cases that Allowed it, and Why it Needs to End

In 1922, United States Supreme Court Justice Oliver Wendell Holmes authored the opinion for the majority in Federal Baseball Club of Baltimore, Inc v. National League of Professional Baseball Clubs. That decision judicially exempted Major League Baseball from the Sherman and Clayton Antitrust Acts, and the organization would take full advantage. Through increasingly nonsensical legal reasoning, this exemption survived into 2022, its 100th anniversary. This paper explains the intricate monopoly Major League Baseball created, the individuals who made the decisions to allow it, and why Congress must pass legislation ending it for good.