Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc.
Split Score
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Case Summary
Disposition
Affirmed in Part
The First Circuit affirmed dismissal of the plaintiffs’ Sherman Act claims against Puerto Rico’s professional baseball league under the longstanding ‘business of baseball’ antitrust exemption. However, it vacated the district court’s dismissal of Puerto Rico antitrust and fair-competition claims and reversed dismissal of a § 1983 due-process claim, holding that state antitrust claims are not categorically pre-empted and that res judicata was applied in error.
Circuit Split Identified
Legal Issue
Whether state (or territorial) antitrust and fair-competition laws are categorically pre-empted by the federal "business of baseball" exemption under the Supremacy Clause, or whether such state claims may proceed absent an independent Commerce Clause barrier.
Circuit Positions
State antitrust regulation of the business of baseball is pre-empted by federal law; Supremacy Clause bars such claims.
No categorical pre-emption; state antitrust claims are not barred unless they impose an impermissible burden on interstate commerce under the Commerce Clause.
Conflict Summary
The Eleventh Circuit holds that federal antitrust policy impliedly pre-empts all state antitrust regulation of the business of baseball (Major League Baseball v. Crist, 331 F.3d 1177 (11th Cir. 2003)), whereas the First Circuit rejects that reading of Flood v. Kuhn and concludes that state or territorial antitrust claims are not automatically pre-empted; instead courts must conduct a Commerce Clause–specific analysis of burdens on interstate commerce before dismissing such claims.