Law School Case Brief
Charles O. Finley & Co. v. Kuhn - 569 F.2d 527 (7th Cir. 1978)
The Commissioner of Baseball has the authority to determine whether any act, transaction, or practice is not in the best interests of baseball, and upon such determination, to take whatever preventive or remedial action he deems appropriate, whether or not the act, transaction, or practice complies with the Major League Rules or involves moral turpitude.
Defendant Bowie K. Kuhn, baseball commissioner, disapproved the assignments of three player contracts by Charles O. Finley & Co., Inc. (Finlay), the owner of the Oakland Athletics baseball club, a member of the American League of Professional Baseball Clubs (Oakland), as inconsistent with the best interests of baseball. Finlay filed suit alleging that Kuhn exceeded his authority in making his decision. Finlay’s complaint alleged seven causes of action. The trial court granted summary judgment to Kuhn on an antitrust claim on the ground that baseball was not subject to federal antitrust laws, and on two constitutional claims on the ground that Finlay failed to allege sufficient nexus between the state and the complained-of activity to constitute state action. The trial court rendered judgment for Kuhn on the remaining four causes.
Is Commissioner of Baseball contractually authorized to disapprove player assignments that he finds to be "not in the best interests of baseball" where neither moral turpitude nor violation of a Major League Rule is involved?
The appellate court affirmed, holding that Kuhn had the authority to determine whether the assignments were in the best interests of baseball, and to take whatever preventive or remedial action he deemed appropriate.
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