2017-08-10

Sports Legends Spencer Haywood and Curt Flood versus the NBA in 1971 and MLB in 1972

Source: Wikipedia

Haywood v. National Basketball Association

401 U.S. 1204 (1971), was a U.S. Supreme Court decision that ruled, 7–2, against the National Basketball Association’s old requirement that a player may not be drafted by an NBA team unless he waited four years (which meant playing at the college level in most cases) following his graduation from high school.

Background

Spencer Haywood turned pro after his sophomore season at the University of Detroit, joining the American Basketball Association’s Denver Rockets and leading the league in scoring (30.0 per game) and rebounding (19.5 per game) in 1969-70 before jumping to the NBA the following season. Seattle SuperSonics owner Sam Schulman signed Haywood to a six-year, $1.5 million contract, ignoring the rule that a player cannot join the league until he is four years out of high school. As a result, the NBA threatened to disallow the contract and implement various punitive sanctions against the SuperSonics.

Procedural History

Haywood challenged this decision by commencing an antitrust action against the NBA. As part of his claim against the NBA, Haywood argued that the conduct of the NBA was a "group boycott" and a violation of the Sherman Antitrust Act. The central issue that had to be determined was whether the NBA draft policy was a restraint on trade and therefore was illegal in accordance with the Sherman Act.

The case was filed in the United States District Court for the Central District of California, which issued an injunction in Haywood's favor,
ruling: “If Haywood is unable to continue to play professional basketball for Seattle, he will suffer irreparable injury in that a substantial part of his playing career will have been dissipated, his physical condition, skills, and coordination will deteriorate from lack of high-level competition, his public acceptance as a super star will diminish to the detriment of his career, his self-esteem, and his pride will have been injured and a great injustice will be perpetrated on him.”

The NBA appealed to the Ninth Circuit Court of Appeals, which stayed the injunction. Joined by the SuperSonics, Haywood appealed to the Supreme Court, which upheld the District Court, reinstated that court's injunction against the NBA, and remanded the case to the District Court for further proceedings.

Impact

Shortly after the Supreme Court's decision, the league and Haywood reached an out-of-court settlement which allowed him to stay with the Sonics permanently.
The decision allowed a significant number of high school graduates and college attendees to make themselves eligible for the NBA Draft before completing four years in college.

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Curt Flood versus Major League Baseball - Link: https://en.wikipedia.org/wiki/Flood_v._Kuhn

Flood v. Kuhn, 407 U.S. 258 (1972), was a United States Supreme Court decision upholding, by a 5–3 margin, the antitrust exemption first granted to Major League Baseball (MLB) in Federal Baseball Club v. National League. It arose from a challenge by St. Louis Cardinals' outfielder Curt Flood when he refused to be traded to the Philadelphia Phillies after the 1969 season. He sought injunctive relief from the reserve clause, which prevented him from negotiating with another team for a year after his contract expired. Named as initial respondents were baseball commissioner Bowie Kuhn, MLB and all of its then-24 member clubs.

Although the Court ruled in baseball's favor 5–3, it admitted the original grounds for the antitrust exemption were tenuous at best, that baseball was indeed interstate commerce for purposes of the act and the exemption was an "anomaly" it had explicitly refused to extend to other professional sports or entertainment. That admission set in motion events which ultimately led to an arbitrator's ruling nullifying the reserve clause and opening the door for free agency in baseball and other sports...

Legacy

The decision is often remembered today as paving the way for free agency in baseball. However, it did so, according to Bill James, only by showing players they could not rely on the courts to strike down the antitrust exemption and the reserve clause along with it. But the effort by a player of Flood's stature did galvanize the players, and according to Marvin Miller it made the general public aware of the reserve clause.

Labor law proved a more fruitful opportunity for the invalidation of the reserve clause. The next year the National Labor Relations Board voted that baseball came under its jurisdiction, and that led to the Seitz decision three years later that Andy Messersmith and Dave McNally were free agents after they had played out a year without signing new contracts. That event is considered the true beginning of baseball free agency.

Read more: https://en.wikipedia.org/wiki/Flood_v._Kuhn

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