The players of Minor League Baseball filed a class-action lawsuit against the Office of the Commissioner of Baseball, Former Commissioner of Baseball, and Major League Baseball’s (MLB) 30 franchises. The court established the fact that they demanded damages from Major League Baseball (MLB) for violating federal antitrust laws (Miranda v. Selig, 2017). The court found that the MLB franchises also operate in Minor League. Thus, although lower league players train and play for lower league clubs, they are listed as MLB players.
Nevertheless, a provision in the contract prohibits players from playing for any other baseball team, independent of whether or not it is included in the franchise. However, teams have the right between MLB franchises to transfer their exclusive rights to a player between them (Miranda v. Selig, 2017). The contract only determines the monthly salary rate for Minor League players for the first season. For each following season, players and clubs should arrange a monthly salary (Miranda v. Selig, 2017). The court determined the fact that, in contrast to Major League Baseball players, Minor League players are not part of a union and therefore need to engage in negotiation on their own.
The Procedural History
The United States District Court for the Northern District of California dismissed the action in a court trial. The Court of Appeals reviews the district court’s order dismissing an action for failure to state a claim de novo. Fed. R. Civ. P. 12(b)(6) (Miranda v. Selig, 2017).
The central question presented by Miranda v. Selig concerns the exemption from federal antitrust law of professional Minor League Baseball. Basically, MLB wage guidelines are not publicly available, but plaintiffs demand that all first-year lower league players earn $1,100 per month and Class A lower league players earn $1,250 per month (Miranda v. Selig, 2017). The plaintiffs allege that Minor League players earn less than $7,500 a year, and some earn as little as $3,000 (Miranda v. Selig, 2017). At the same time, they demand compensation and salary for spring training, during which they work fifty to sixty hours a week.
Curt Flood Act of 1998, Stat. 2824 (codified at *1242 15 U.S.C. § 266) (Miranda v. Selig, 2017).
The judges examined the plaintiffs’ statements and the current law on the issue. The court has jurisdiction under 28 U.S.C. § 1291 and should use Supreme Court and Ninth Circuit precedents upholding baseball’s exemption from federal antitrust laws (Miranda v. Selig, 2017, p. 5). The Curt Flood Act established that “the conduct, practices, or agreements of persons engaged in organized professional baseball have a direct effect on the operations of Major League Baseball players and are subject to the antitrust laws” 15 U.S.C. § 26b(a) (Miranda v. Selig, 2017, p. 5). However, it correctly preserved the exemption from federal monopoly laws relating to hiring Minor League Baseball players. The Court of Appeals adhered to the decisions of Hutto v. Davis, 454 U.S. 370, 375, 102 S.Ct. 703, 70 L.Ed.2d 556, also the decisions of Nunez-Reyes v. Holder, 646 F.3d 684, 692 (9th Cir. 2011) (Miranda v. Selig, 2017). They form the precedent in this case and affirm the lower court’s decisions.
According to Supreme Court precedents, lower court decisions, and the Curt Flood Act of 1998, Minor Leagues Baseball is directly subject to an exemption from federal antitrust laws.
Miranda v. Selig (2017) 860 F.3d 1237