Of course, the scheme requires constantly repeated traveling on the part of the clubs, which is provided for, controlled, and disciplined by the organizations, and this, it is said, means commerce among the states.

But the fact that, in order to give the exhibitions, the Leagues must induce free persons to cross state lines and must arrange and pay for their doing so is not enough to change the character of the business.

If we are right, the plaintiff's business is to be described in the same way, and the restrictions by contract that prevented the plaintiff from getting players to break their bargains and the other conduct charged against the defendants were not an interference with commerce among the states.This case is the main reason why MLB has not faced any competitor leagues since 1922, and MLB, to date, remains the only American sports league with such an antitrust exemption.

[2][3] The case was reaffirmed in Toolson v. New York Yankees, Inc.[4] In Flood v. Kuhn, the Court partially reversed, and found Major League Baseball to be engaged in interstate commerce.

[5] In 2016's Direct Marketing Association v. Brohl, the Tenth Circuit's Neil Gorsuch cited Federal Baseball and Toolson in his concurrence as one of the "precedential islands", along with Bellas Hess, that] manage[s] to survive indefinitely even when surrounded by a sea of contrary law….