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Court Declines to Revisit Baseball's Century-Old Antitrust Exemption

Case: Cangrejeros de Santurce Baseball Club, LLC, et al. v. Liga de Béisbol Professional de Puerto Rico, Inc., et al., No. 25-416

Lower Court: First Circuit

Docketed: 2025-10-07

Status: Denied

Question Presented: Ordinarily, there would be no question that collusion among ostensible adversaries to expel a competitor from a market would give rise to federal antitrust liability. But not when it comes to the business of baseball, which for longer than a century has enjoyed the protection of an illogical, sport-specific antitrust exemption. The baseball antitrust exemption’s genesis is Federal Baseball Club of Baltimore v. National League of Professional Baseball Clubs, 259 U.S. 200 (1922), decided at the h...

On March 2, 2026, the Supreme Court denied certiorari in Cangrejeros de Santurce Baseball Club, LLC v. Liga de Béisbol Professional de Puerto Rico, Inc., No. 25-416. The denial came after two conferences, suggesting the Court gave the petition more than routine consideration before declining to take it up. Three amicus briefs had been filed, including submissions from antitrust and sports law professors and the Major League Baseball Players Association, signaling that the legal community viewed the question as genuinely open.

The underlying dispute involved allegations that the Liga de Béisbol Professional de Puerto Rico and related parties colluded to expel the Cangrejeros de Santurce from the league. The petitioners argued that such conduct would plainly violate federal antitrust law in any other commercial context. The baseball exemption, however, traces to the Court’s 1922 decision in Federal Baseball Club of Baltimore v. National League, which held that the business of baseball did not constitute interstate commerce. The Court reaffirmed the exemption in Toolson v. New York Yankees (1953) and again in Flood v. Kuhn (1972).

Petitioner Jeffrey L. Kessler framed the questions sharply: should the Court overrule Federal Baseball and its progeny, or at minimum narrow the exemption’s scope? The two-conference distribution indicated the justices deliberated, yet the denial suggests insufficient appetite for reopening a doctrine the Court has twice declined to discard.

The denial preserves a legal anomaly that courts and commentators have long criticized as inconsistent with modern Commerce Clause doctrine. Practitioners and scholars tracking sports antitrust issues can follow further developments at SCOTUSBlog.