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Phila. Ball Club, Ltd. v. Lajoie - 202 Pa. 210, 51 A. 973 (1902)

Rule:

A court of equity will act where nothing can answer the justice of the case but the performance of the contract in specie; and this even where the subject of the contract is what under ordinary circumstances would be only an article of merchandise. In such a case, when owing to special features, the contract involves peculiar convenience or advantage, or where the loss would be a matter of uncertainty, then the breach may be deemed to cause irreparable injury.

Facts:

Lajoie had contracted to serve the Philadelphia Baseball Club, Ltd. as a baseball player for a stipulated time. During that period Lajoie was not to play for any other club. He violated his agreement, however, during the term of his engagement when, in disregard of his contract, he arranged to play for another rival organization. The baseball club by means of the bill sought to restrain him. The trial court refused an injunction, holding that to warrant interference, the player's services had to be unique, extraordinary, and of such a character as to render it impossible to replace him, such that his breach would have resulted in irreparable loss to the baseball club. The baseball club appealed.

Issue:

Did the trial court err in refusing to issue an injunction against the player for breaching his contract and playing for another team?

Answer:

Yes

Conclusion:

The court reversed, reinstated the bill, and held that where one person agrees to render personal services to another that require and presuppose a special knowledge, skill, and ability in the employee, so that in case of a default the same service could not easily be obtained from others, the damages for breach of such contract could not be estimated with any certainty, and the employer could not, by means of any damages, purchase the same service in the labor market.

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