Wyckoff v. Office of the Commissioner of Baseball
705 F. App'x 26
| 2d Cir. | 2017Background
- Plaintiffs Jordan Wyckoff and Darwin Cox, professional baseball scouts, sued MLB, the Office of the Commissioner, the Commissioners, and the 30 MLB clubs alleging an antitrust conspiracy to depress competition for scouts’ labor and violations of the Sherman Act, New York Donnelly Act, and FLSA.
- The district court dismissed the complaint under Rule 12(b)(6); plaintiffs appealed the dismissal to the Second Circuit.
- Plaintiffs alleged scouts evaluate and supply player-evaluation information that franchises use for player acquisition decisions, and contend defendants conspired to reduce competition and wages for scouts.
- Defendants argued the conduct at issue is shielded by baseball’s long-recognized antitrust exemption and that plaintiffs are part of the ‘‘business of baseball.’’
- The Second Circuit reviewed dismissal de novo, accepted factual allegations as true, and applied binding Supreme Court and Second Circuit precedent on baseball’s antitrust exemption.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants’ conduct is subject to Sherman Act scrutiny or exempt as the business of baseball | Scouts (Wyckoff) argue defendants conspired to decrease competition for scouts, violating Sherman Act and Donnelly Act | MLB/Franchises argue baseball’s judicially created antitrust exemption applies and scouts are part of the business of baseball | Held: Exemption applies; scouts are involved in the business of baseball, so antitrust claims fail |
| Whether plaintiffs fall within the Curt Flood Act exception | Plaintiffs contend they are not MLB players and thus should be entitled to antitrust protection | Defendants note Curt Flood Act narrowly confers antitrust rights only to major league players, excluding other employees | Held: Curt Flood Act does not extend antitrust protection to scouts; it is limited to players |
| Whether plaintiffs adequately pleaded a claim under state Donnelly Act mirroring federal antitrust law | Plaintiffs argue state antitrust claims survive even if federal claim is barred | Defendants argue state law claim is similarly precluded by baseball exemption and by plaintiffs’ status | Held: Donnelly Act claim fails for same reason as federal antitrust claim |
| Whether the complaint should survive Rule 12(b)(6) given plaintiffs’ own allegations about scouts’ role | Plaintiffs argue factual allegations show they are not part of core baseball business and thus not exempt | Defendants argue plaintiffs’ allegations show scouts provide essential player-evaluation services to franchises | Held: Plaintiffs’ allegations confirm scouts are involved in the business of baseball; dismissal proper |
Key Cases Cited
- Fed. Baseball Club of Baltimore v. National League of Professional Baseball Clubs, 259 U.S. 200 (1922) (establishes baseball’s judicial antitrust exemption)
- Toolson v. New York Yankees, Inc., 346 U.S. 356 (1953) (reaffirmed baseball exemption)
- Flood v. Kuhn, 407 U.S. 258 (1972) (acknowledged exemption as an ‘‘aberration’’ but adhered to precedent)
- Salerno v. American League of Professional Baseball Clubs, 429 F.2d 1003 (2d Cir. 1970) (applied baseball exemption to professional baseball officials)
- Stratte-McClure v. Morgan Stanley, 776 F.3d 94 (2d Cir. 2015) (standard of review for Rule 12(b)(6) dismissal)
- Adelson v. Harris, 774 F.3d 803 (2d Cir. 2014) (accept factual allegations as true on motion to dismiss)