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MLB Antitrust Exemption Covers Other Pro Baseball, Rules Court

Published

5 months ago

July 27, 2025

Baseball’s antitrust exemption, which the U.S. Supreme Court created in 1922, is typically thought of as MLB’s antitrust exemption.

In a decision from earlier this week, the U.S. Court of Appeals for the First Circuit made clear the “business of baseball” exemption extends throughout professional baseball—and not just MLB.

The ruling comes at a time when college sports is evolving (or devolving, depending on whom you ask) into a model that resembles professional sports, with NIL and House settlement revenue shares. The ruling could thus have far-reaching implications beyond what is traditionally viewed as pro baseball, perhaps by including the evolving college game under the overall baseball antitrust umbrella.

A few years ago, Thomas Axon, a former owner-operator of the Cangrejeros de Santurce Baseball Club, and others sued Liga de Béisbol Profesional de Puerto Rico—the top pro baseball league in the U.S. territory—and league officials. Axon accused the league and other teams’ owners of conspiring to remove him and his associated businesses from the league and taking away his control of the franchise. The case involves Sherman Act claims and those that arise under other federal and Puerto Rico statutes.

U.S. District Judge William Young dismissed the lawsuit in 2023, reasoning the defendants are exempt from the antitrust claims since they involve professional baseball. Young stressed the U.S. Supreme Court’s decision in Federal Baseball Club v. National League (2022). Writing for the Court, Justice Oliver Wendell Holmes Jr. concluded that federal antitrust claims brought against MLB were not appropriate since federal antitrust law requires interstate commerce, meaning the movement of people, goods and services that cross from one state into another. MLB games are, of course, only played in one state.

Legal historians and other commentators have long criticized Holmes’ logic. Even though MLB games are played intrastate, they necessarily involve interstate activity. Players and team personnel, along with equipment and broadcasts, travel across states to make games possible. In the early 1920s, however, the Court adopted a narrow view of interstate commerce and Federal Baseball Club was not out of step with that line of thinking.

Years later, the Supreme Court refused to extend the baseball exemption to other sports, including football, basketball and boxing. And, when given the opportunity to reverse the baseball exemption in Curt Flood v. Bowie Kuhn (1972), the Supreme Court declined. The Court instead invoked the principle of stare decisis, which is Latin for “to stand by things decided.” It means courts, including SCOTUS, must follow Supreme Court precedent.

Young underscored that in Federal Baseball Club, the Court referred to the “business” of “giving exhibitions of baseball.” This depiction didn’t limit the exemption to MLB but instead, at least as worded, extends throughout professional baseball.

In an opinion authored by Chief Judge David J. Barron and joined by Judges O. Rogeriee Thompson and Gustavo A. Gelpí, the First Circuit agreed with Young that the exemption applies.

Barron acknowledged widespread criticism of the exemption as “unrealistic, inconsistent, or illogical,” but stressed that changing the exemption requires legislative action. In 1998, Congress passed, and President Bill Clinton signed into law, the Curt Flood Act. The act narrowed the exemption to no longer apply to MLB players’ employment. Yet to this day, the exemption still applies to other pro baseball topics.

Barron wrote that even if the exemption is substantively problematic, it “remains in place” on account of stare decisis. He also reasoned that the exemption does not apply “only to MLB and its affiliates,” since that is not what the Supreme Court actually said in 1922.

“Federal Baseball,” Barron wrote, “did not describe the ‘business of baseball’ exemption in terms of the specific professional baseball leagues that were parties to that case or to any specific league at all.” He added that the Court “defined the exemption in terms of an activity,” with the activity being the business of giving exhibitions of baseball.

Barron went on to cite other Supreme Court cases, including Toolson v. New York Yankees (1953), where the Court characterized the exemption as concerning “public baseball games for profit between clubs of professional baseball players.”

The litigation is not over. The First Circuit found that while the federal antitrust claims are off the board, the other claims aren’t exempted. The litigation for those claims will continue at the trial court level.

The interpretation of the baseball exemption as including pro leagues beyond MLB is especially intriguing as college sports morph into something akin to pro sports. College athletes, including college baseball players, can sign NIL deals that are akin to endorsement deals for MLB players. Some of those athletes will also receive direct pay from schools in the form of revenue sharing, a byproduct of the House settlement. The further college baseball transforms into professional baseball, particularly if college athletes are recognized as employees, the more plausible organizers of college baseball could rely on the baseball exemption to combat antitrust claims.

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Miami NIL financial commitment in 2026

Published

5 minutes ago

December 25, 2025

Your Sports Nation

The landscape is evolving fast, and more teams saw the success of Miami, Texas Tech, Oregon, and Indiana in the portal, and will become more
competitive. Texas Tech is doubling down, and we can expect more competition even inside the ACC with Clemson and VaTech. Point here, is what was good and competitive in 2025, wont be enough in 2026. Solid HS recruiting helps, but just look at the impact of our portal class this season. January 2nd through the 10th is going to be crucial, and hope we have our ducks in a row right now. The financial commitment needs to grow to be on par with Texas Tech and Oregon.

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College football: Four key Gophers coming back in unique NIL campaign

Published

1 hour ago

December 25, 2025

Your Sports Nation

PHOENIX — Four important Gopher football players were part of a unique media campaign on Tuesday.

Offensive linemen Greg Johnson and Nathan Roy, and defensive backs John Nestor and Kerry Brown allowed the Gophers’ NIL collective, Dinkytown Athletes, to share news they will play in the Rate Bowl against New Mexico on Friday, and will return to Minnesota for the 2026 season.

The social media posts were “presented by Cub Foods,” and those players will be recipients of the grocer’s NIL contribution next year. Dinkytown Athletes serves as a subcontractor.

Athletics Director Mark Coyle called Cub Foods a “foundational partner” of Gopher sports.

“That is how we take the next step, with that type of involvement with NIL side of it,” Coyle told the Pioneer Press. “We are so grateful for their support.”

A few more current Gopher players are expected to join the Cub Foods campaign after the bowl game. But if players on the current roster aren’t included in this specific rollout, that doesn’t necessarily mean they are leaving the U to go into the transfer portal.

For instance, quarterback Drake Lindsey said, independently, two weeks ago that he would return to Minnesota for his redshirt sophomore season in 2026. Other current players have shared they will be back with the Gophers next year.

Meanwhile, the futures of defensive end Anthony Smith, safety Koi Perich and running back Darius Taylor have yet to be shared. Smith and Taylor said Wednesday they have not yet made decisions on their plans for 2026; both are in line to play in the bowl game at Chase Field.

“I really haven’t thought about that stuff,” Taylor said. “I’m just worried about the game. I will figure all that out after the game.”

Smith said he hasn’t ruled out entering the transfer portal. “I don’t know,” he said.

Johnson, who started all 12 regular-season games at guard, will return for his senior season next fall. The Prior Lake native played nearly 700 snaps and was Minnesota’s highest-graded starting offensive lineman in 2025 (75.3 overall mark, per Pro Football Focus).

“Being from Minnesota, I personally didn’t have any thoughts of going elsewhere,” Johnson said. “I think Drake really set the tone for the team. This is Drake’s team. He’s our leader and it’s easy to come back and want to play for a guy like that.”

Roy stepped in as the U’s left tackle during his redshirt freshman year with aplomb, playing a team-high 702 snaps with a 69.0 grade from PFF. The Mukwanago, Wis., native will be back for his redshirt sophomore year.

Nestor transferred in from the Iowa Hawkeyes last year, and the Chicago native started 10 of 12 games as Minnesota’s most-reliable corner. He had a team-high five interceptions, adding 47 tackles in 538 total snaps. He will be a senior in 2026.

Brown continued as a linchpin in Minnesota’s defense for second straight season. The safety and nickel back from Naples, Fla., was fourth on team with 55 tackles and added two interceptions in 579 snaps. He will return for his redshirt junior year.

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Three Mizzou staffers following Kirby Moore to Washington State

Published

2 hours ago

December 25, 2025

Your Sports Nation

When Kirby Moore got the Washington State head coaching job, Eli Drinkwitz knew a few members of his staff would likely be headed to Pullman soon.

“Moving forward, could lose a couple more people off our staff from analyst roles, as coach Moore finalizes and puts his staff together,” Drinkwitz said on December 16. “It shouldn’t change the dynamic of what we do at all.”

Three of those moves were reported on Wednesday morning by Chris Hummer and Matt Zenitz of CBS and 247Sports.

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The first is Tiger tight ends coach Derham Cato. Cato has coached Mizzou’s tight ends for the last three seasons. He spent six years at Washington, including an overlap with Moore when Moore was a graduate assistant for the Huskies. PowerMizzou.com had alerted subscribers to this move being likely a week ago.

The second coach is assistant offensive line coach Jack Abercrombie. Hummer and Zenitz report that Abercrombie will be the full-time offensive line coach for Moore with Washington State. Prior to his time at Mizzou, Abercrombie was on staff at VMI.

The final Mizzou to Washington State move is a front office move. Brad Larrondo, who has served as the CEO of Every True Tiger Brands, which is Missouri’s third-part partner for name, image and likeness deals. In his role, Larrondo helps Mizzou athletes line up NIL deals and also negotiates NIL and revenue sharing contracts for Mizzou football and men’s basketball players. Larrondo came to Missouri as Drinkwitz’s Director of Football External Relations and Recruiting in March of 2023. Prior to that, he had been the Chief of Staff at Auburn.

Larrondo had spent the previous 28 years in the athletic administration at Boise State, which is just 300 miles from Pullman. He still has family in Boise and sources told PowerMizzou.com the move to Washington State is heavily based in family reasons.

Larrondo’s position is technically not a University or a football program hire. However, the position works very closely with both and whoever replaces him will do so with influence and blessing from both of those entities. Missouri plays Virginia in the Taxslayer Gator Bowl on Saturday night. Any personnel moves or replacements will almost certainly not come until after that game.

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Missouri Damon Wilson files countersuit against Georgia in NIL case

Published

3 hours ago

December 25, 2025

Your Sports Nation

Updated Dec. 24, 2025, 11:28 a.m. ET

Missouri football defensive end Damon Wilson has sued Georgia athletics, a move that counters a Georgia lawsuit filed against Wilson earlier this year and intensifies what was already a novel and likely first-of-its-kind case over an NIL contract dispute.

A 42-page document reviewed by the Columbia Daily Tribune was filed in Boone County on Tuesday.

Georgia is attempting to take Wilson into arbitration and is seeking $390,000 in liquidated damages from the star edge rusher, who transferred to the Tigers in January 2025, over what the university views as an unfulfilled contract with the Bulldogs’ former NIL collective, Classic City Collective.

In response, escalating what was already an attempt at a potentially precedent-setting case, Wilson’s attorneys allege his former team “falsely (told) at least three programs” unnamed Power Four teams that “Wilson would be subject to a $1.2 million buyout.”

The suit also alleges Georgia violated a confidentiality provision in Wilson’s term sheet, which was provided as part of the UGA lawsuit in a public court filing.

Wilson’s suit argues he also was urged to sign the term sheet without legal counsel, and that Georgia did not “immediately submit his name to the transfer portal” but instead “launched an all-out offensive to convince Wilson to remain at Georgia.”

Also of note: The suit argues the term sheet Wilson signed states it would “be used to create a legally binding document” and therefore is not enforceable in its current format, and that he was urged to “seek legal counsel” before the agreement was finalized.

If the document is determined not to be finalized, it is quite likely Wilson will not owe Georgia the $390,000 it seeks.

Per The Athletic, Wilson is seeking “a ‘fair and reasonable amount of damages’ for the ‘financial and reputational harm he has suffered’ along with legal fees” from Georgia.

“Georgia appears intent on making an example of someone, they just picked the wrong person,” Jeff Jensen, one of Wilson’s attorneys, said to the Columbia Daily Tribune. “Damon never had a contract with them. I don’t see how Georgia thinks intimidation and litigation will help their recruitment efforts — maybe players could bring lawyers with them to practice.”

Multiple Missouri representatives, including a team spokesperson and athletic director Laird Veatch, have declined to comment on Wilson’s lawsuit. The Georgia lawsuit is not against the University of Missouri; it is only against Wilson.

“This matter involves pending litigation, and we have no comment at this time,” Georgia spokesperson Steven Drummond told USA TODAY on Tuesday. “We refer you to our previous statement.”

The previous Georgia statement in question: “When the University of Georgia Athletic Association enters binding agreements with student-athletes, we honor our commitments and expect student-athletes to do the same.”

Georgia has argued Wilson signed a contract — a common practice in the NIL era — with what was then Georgia’s main, but now-shuttered, NIL and marketing arm, Classic City Collective, in December 2024.

That collective has since shut down, as Georgia has partnered with Learfield to negotiate and facilitate NIL deals in the revenue-sharing era.

The report, citing documents attached to Georgia’s legal filings, shows that Wilson signed a 14-month term sheet worth $500,000 with the Bulldogs. He was set to earn monthly payments of $30,000 through the end of the contract, as well as two $40,000 bonus payments.

Before announcing his intention to transfer in January, he reportedly was paid $30,000.

The contract states if Wilson left the team or transferred, as he ultimately did to Missouri, he would owe the collective that issued the payments a lump sum equal to the amount remaining on his deal.

The bonus payments seemingly were not included, which brings that total to the $390,000 that Georgia is now seeking in court.

Wilson was paid only a fraction of that sum, but the university argues he owes the full amount in damages. It’s unclear why Georgia is claiming it is owed the full amount in liquidated damages.

According to documents viewed by the Tribune through the Georgia courts records system, Georgia filed an “application to compel arbitration” on Oct. 17 in the Clarke County Superior Court, which includes Athens and the University of Georgia. Wilson was served with a summons to appear in court, according to documents, on Nov. 19, three days before the Tigers faced Oklahoma.

Wilson spent his freshman and sophomore seasons at Georgia. He transferred to Missouri ahead of spring camp in 2025 and has emerged as one of the top pass rushers in the SEC.

Per Pro Football Focus, Wilson generated 49 pressures on opposing quarterbacks this season, which was the second-most in the SEC behind only Colin Simmons at Texas. He’s listed at 6-4, 250 pounds and could declare for the 2026 NFL Draft, where he would likely be a Day 1 or 2 pick.

This case marks the first time a school has taken a player to court over an NIL buyout. It also looks likely to be the first time a player has filed suit against a school over NIL.

Missouri has multiple players on two-year contracts. Part of that is in the hope they do not move on after one season.

If Georgia’s arbitration case against Wilson is successful, that would be a groundbreaking ruling in college athletics that could give more weight to liquidated damages clauses in athlete contracts.

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College Football Playoff team loses key starter to NCAA transfer portal

Published

4 hours ago

December 25, 2025

Your Sports Nation

The first round of the College Football Playoff is in the books. Eight teams remain in the hunt to win it all, with Miami and Ohio State kicking off the quarterfinals slate in the Goodyear Cotton Bowl on December 31.

There were quite a few memorable games in the opening round of the playoffs, including Miami’s hard-fought victory against Texas A&M and Alabama’s wild comeback to secure a road win over Oklahoma.

The lone blowout came from Ole Miss over Tulane, winning 41-10 over the Green Wave. Both programs are in transition after their head coaches were hired away by other schools. The Green Wave, in particular, has seen some attrition since concluding its season last week.

Another Tulane Starter Enters Transfer Portal

On Wednesday afternoon, redshirt sophomore cornerback Jahiem Johnson announced his plans to move on after three seasons at Tulane, per On3’s Haye Fawcett.

Johnson developed into a productive defender for the Green Wave in 2025, starting in all 14 games. He totaled 42 tackles, 1 tackle for loss, 1 forced fumble, 9 pass deflections, and 4 interceptions. Johnson’s 9 pass deflections led the American Conference.

He deflected a pass in 6 different games and recorded a pick in 4 separate outings. In Tulane’s conference championship victory against North Texas, Johnson tied his season-high with 5 tackles, 1 pass deflection, and 1 interception.

The Louisiana native played the most snaps (834 snaps) of any player on Tulane’s defense. He was the third-highest-graded player on the unit (77.1 overall grade), per Pro Football Focus.

Johnson signed with Tulane as a three-star prospect in the 2023 class, joining the program under former head coach Willie Fritz. He redshirted as a true freshman, sticking with the Green Wave when Jon Sumrall took over.

In 2024, appeared in 14 games as a reserve, totaling 4 tackles and 2 pass deflections. Johnson’s rise this past season resulted in him earning honorable mention conference honors.

Johnson is the fifth starter to transfer from Tulane, joining defensive end Santana Hopper, linebacker Harvey Dyson, defensive tackle Tre’Von McAlpine, and running back Javin Gordon in the portal.

Sumrall was hired away from the Green Wave to be the next head coach of the Florida Gators. Considering Johnson’s breakout campaign, he may want to continue playing for a familiar face if that option is on the table.

Four key Gophers will be back in 2026

Published

5 hours ago

December 25, 2025

Your Sports Nation

PHOENIX — Four important Gopher football players were part of a unique media campaign on Tuesday.

The social media posts were “presented by Cub Foods,” and those players will be recipients of the grocer’s NIL contribution next year. Dinkytown Athletes serves as a subcontractor.

Athletics Director Mark Coyle called Cub Foods a “foundational partner” of Gopher sports.

“That is how we take the next step, with that type of involvement with NIL side of it,” Coyle told the Pioneer Press. “We are so grateful for their support.”

“I really haven’t thought about that stuff,” Taylor said. “I’m just worried about the game. I will figure all that out after the game.”

Smith said he hasn’t ruled out entering the transfer portal. “I don’t know,” he said.