In December 2021, upon the expiration of the collective bargaining agreement (CBA) between Major League Baseball (MLB) and the Major League Baseball Players' Association (MLBPA), MLB owners voted unanimously for a lockout, beginning the ninth work stoppage in MLB history. With the upcoming season in jeopardy, the lockout ended on March 10, 2022, as the sides resolved their differences and signed a new CBA. While all the sport's previous work stoppages—beginning with a 1972 players' strike— have occurred in the last half-century, labor disputes between professional baseball players and team owners have been a near constant since the advent of the sport.
This spotlight will explore two areas of controversy between players and owners that frequently brought baseball into the federal courts between the late nineteenth and late twentieth centuries: the enforceability of a standard contract provision known as the "reserve clause," and the related question of whether professional baseball was governed by federal antitrust laws. The resolution of these issues played a major role in shaping the "national pastime,” particularly in determining the balance of power between players and their employers.
From the earliest days of professional baseball in the 1870s until the creation of free agency in the 1970s, the reserve clause was a subject of controversy (as it became in other American professional sports leagues established in the twentieth century). The clause, first implemented by the National League after its fourth season in 1879, provided in essence that a team was entitled to reserve the services of a player in perpetuity. When a player’s contract expired, the team for which he played had the exclusive right to negotiate with him for a new contract. The player had little bargaining power, for his only alternative to reaching agreement with his team was not to play. The team to which the player was bound could also trade him or sell his contract to another team without his consent. By forbidding the voluntary movement of players to other teams, the reserve clause kept salaries artificially low and gave players no say over where they performed their work. Team owners justified the clause on the grounds that without it, the wealthiest teams would sign all the best players, destroying competitive balance and ruining the sport. At first, a league rule (which every player contract incorporated by reference) allowed each team to reserve five players of its choosing. By 1887, the reserve clause appeared explicitly in player contracts and permitted a team to reserve its entire roster, then consisting of fourteen players.