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Atlanta Nat'l League Baseball Club, Inc. v. Kuhn - 432 F. Supp. 1213 (N.D. Ga. 1977)

Rule:

The sum total of punitive sanctions available to the Commissioner of Baseball are those specifically itemized in the Major League Agreement, art. I, § 3, or under the Major League Rules, such as Rule 50.

Facts:

The Major League Baseball Players and the Major League Club Owners entered into a collective bargaining agreement, whereby negotiation rights with each free agent could be drafted by up to 12 teams, each of which were then given negotiation rights for that player. During the post-season period, the club of record had exclusive negotiating rights with the free agent, although, the other clubs were allowed to talk with the free agent or his representative about the merits of contracting with a particular team provided that the Club and the free agent shall not negotiate terms of contract with each other. Plaintiff Ted Turner, who was the Chief Executive Officer of plaintiff Atlanta National League Baseball Club (“Atlanta Club”), attended a cocktail party in New York City sponsored by the New York Yankees Club, and there engaged a conversation with Robert Lurie, the co-owner of the San Francisco club. In the presence of several media representatives, Turner told Lurie that he would do anything to get Gary Matthews (who was then completing his option year with the San Francisco club) and that he would go as high as he had to. Turner’s comments were reported by a few San Francisco newspapers. Lurie filed a complaint concerning these statements with the Commissioner, who then concluded that Turner’s statements had the effect of subverting the collective bargaining agreement and the re-entry draft procedures adopted pursuant to it. Consequently, the Commissioner decided to suspend Turner from baseball for one year, and decided that the Atlanta Club would not be entitled to exercise its first round draft choice in the amateur free agent draft. Thereafter, Turner and the Atlanta Club filed the present action, challenging defendant Commissioner’s authority to impose the aforementioned sanctions.

Issue:

  1. Did the Commissioner have the authority to impose sanctions on Turner and Atlanta Club?
  2. Were the sanctions imposed by the Commissioner proper?

Answer:

1) Yes. 2) No, as to the deprivation of the club’s first round draft choice.

Conclusion:

The Court noted that the Commissioner had ample authority to punish clubs and owners for acts considered "not in the best interests of baseball." According to the Court, the Commissioner has all the attributes of a benevolent but absolute despot and all the disciplinary powers of the proverbial die However, the Court held that the sum total of punitive sanctions available to the Commissioner were those specifically itemized in the Major League Agreement or under the Major League Rules and that deprivation of a draft choice was not one of them. As such, the Court upheld Turner’s suspension from baseball for one year, but found that the deprivation of the club's first round draft choice was ultra vires and, therefore, void.

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