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The business of giving exhibitions of baseball is purely a state affair. The fact that in order to give the exhibitions the baseball leagues must induce free persons to cross state lines and must arrange and pay for their doing so is not enough to change the character of the business.
Federal Baseball Club of Baltimore (“club”) brought an antitrust action against The National League of Professional Base Ball Clubs (“National League”), alleging that they had conspired to monopolize the baseball business by purchasing or otherwise inducing all other clubs in the club's former league to leave that league. The club obtained a verdict for $ 80,000 in the trial court and a judgment for treble the amount was entered. On appeal, however, after an elaborate discussion, the appellate court held that National League’s conduct did not fall within violations of the Sherman Act. The club brought the case to the Supreme Court.
Did National League’s monopoly interfere with interstate commerce?
The Court held that that the conduct charged against National League was not an interference with interstate commerce, as prohibited by the Sherman Act. Although competitions between the various clubs required extensive and frequent travel across state lines of players and officials, such travel was merely incidental to the baseball competitions. The baseball competitions were not commerce, and thus, baseball was purely a state affair. As a state affair, the professional baseball business was not subject to federal antitrust law.