Judge Hints at Split Ruling in Minor League Wage Lawsuit

The parties in the minor league wage litigation were in court last Friday to debate two motions filed by the MLB defendants, and by the end of the hearing Judge Joseph Spero suggested that he was currently leaning towards issuing a split decision.  As a refresher, the litigation involves claims by two groups of former minor league players contending that MLB and its teams’ pay practices violate the Fair Labor Standards Act (FLSA), with many minor leaguers making less than the federally guaranteed minimum wage once all of their work-related duties have been accounted for.

MLB responded to these claims in several ways.  Of particular note for present purposes, all 30 MLB teams asked the court to transfer the case from California to a federal court in Florida, which they argued would be a more convenient venue for the trial.  In reality, MLB was hoping to take advantage of favorable legal precedents, as Florida courts have previously held that minor league baseball teams are seasonal operations immune from the FLSA’s minimum wage and overtime requirements.

During Friday’s hearing, however, Judge Spero indicated that he was unlikely to transfer the case.  This is a significant victory for the minor league plaintiffs.  Had the case been transferred, the Florida court would be bound by the earlier precedent mentioned above, and as a result the new court would have likely dismissed the case against MLB in relatively short order.  Should that have happened, the minor league plaintiffs would then have had to hope that the U.S. Supreme Court would be willing to take the case in order to overturn the Florida precedent.  Barring Supreme Court intervention, the minor leaguers would have had to proceed against MLB only under state law, claims that would have been less effective at securing the nationwide reform the plaintiffs are hoping to achieve.

At the same time, though, Judge Spero also suggested that he was currently leaning in favor of granting a motion to dismiss the case filed by 11 MLB teams (the Orioles, Nationals, Yankees, Rays, Braves, White Sox, Indians, Pirates, Phillies, Tigers, and Red Sox).  These teams had argued that they were not subject to the California court’s jurisdiction because they do not maintain any business presence in the state.  In particular, unlike the other 19 MLB teams, these 11 are not currently affiliated with any California minor league teams.  The plaintiffs had argued that these teams do employ scouts in California, while also routinely traveling to the state to play MLB games.  Judge Spero, however, seems to believe that these contacts are too limited to justify forcing the 11 teams to defend themselves in California court.

Rather than dismiss the teams from the case, though, Judge Spero gave the plaintiffs the opportunity to present additional evidence establishing the teams’ link to California.  In particular, he suggested that the plaintiffs identify minor leaguers who played in California for the 11 teams and are willing to participate in the wage litigation.

If the plaintiffs can find such players, it appears that they will be able to proceed with the case against all 30 teams in California.  If not, then the minor leaguers may be forced to move forward against only a smaller subset of MLB clubs. Ultimately, this difference may prove less significant than it at first seems, as a victory in the case by the plaintiffs against 19 MLB teams would likely still result in major reform to the entire league’s minor league pay practices.  But securing a dismissal would still allow the 11 affected teams to avoid paying damages for past violations of the law (assuming the plaintiffs don’t file a second suit against those teams in another jurisdiction), a potentially significant cost savings.





Nathaniel Grow is an Associate Professor of Business Law and Ethics and the Yormark Family Director of the Sports Industry Workshop at Indiana University's Kelley School of Business. He is the author of Baseball on Trial: The Origin of Baseball's Antitrust Exemption, as well as a number of sports-related law review articles. You can follow him on Twitter @NathanielGrow. The views expressed are solely those of the author and do not express the views or opinions of Indiana University.

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DrBGiantsfan
9 years ago

What is really sad here is the obvious fact that an industry awash in unprecedented amounts of money even bothering to fight this instead of just doing the right thing, paying up and reforming minor league payscales and work conditions.

Hopefully this will become an area of interest for the new commissioner. It seems that one way to make a career in baseball more attractive to young people is to create a situation where they can earn a livable wage playing in the minor leagues.