Did the Dodgers Ruin Baseball? Why MLB’s Antitrust Exemption Stands in the Way of a More Competitive League.

After the Los Angeles Dodgers’ series win over the Milwaukee Brewers in the National League Championship Series, Dodgers manager, Dave Roberts, remembered that, “[b]efore the season started, they said, ‘The Dodgers are ruining baseball … Let’s get four more wins and really ruin baseball. Let’s go!’”[1] Because of this win, Roberts and the Dodgers made good on their promise by going on to win their second straight World Series.[2] No, the Dodgers did not ruin baseball, but their dominance is representative of the growing disparity in competition between large and small-market teams.

Over the last ten years, the teams with the most playoff wins are usually also the teams with the highest payrolls in Major League Baseball (MLB), typically coming from cities with large-markets like New York, Los Angeles, and Atlanta.[3] A potential solution to this issue could be to allow less competitive, small-market teams to relocate to larger cities in order to raise their revenue and, therefore, be able to spend more on better players to compete. Standing in the way of this reallocation is the league’s restrictive rule that requires 23 out of the 30 teams in the MLB to favor an application to a new city.[4] The MLB is able to enact this type of uncompetitive rule because they enjoy an exemption from certain federal antitrust regulations. Thus, the antitrust exemption curbs competition by restricting teams from moving to locations where they can maximize their fanbase and potential earning power.[5]

The MLB’s antitrust exemption finds its origins in the U.S. Supreme Court case Federal Baseball Club v. National League.[6] There, the Court concluded that professional baseball was not considered “interstate commerce” and, therefore, the sport does not fall under the rules of the Sherman Antitrust Act.[7] The Court continued to uphold the MLB’s general exemption in its subsequent decisions in Toolson v. New York Yankees and Flood v. Kuhn.[8] Seeing a need for resolution, Congress eventually decided to take action on the issue by passing the Curt Flood Act in 1998.[9] The Act had finally instituted federal antitrust laws to the MLB, proclaiming:

“[T]he conduct, acts, practices, or agreements of persons in the business of organized professional major league baseball directly relating to or affecting employment of major league baseball players to play baseball at the major league level are subject to the antitrust laws to the same extent such conduct, acts, practices, or agreements would be subject to the antitrust laws if engaged in by persons in any other professional sports business affecting interstate commerce.”[10]

While seemingly giving rise to a broad sweep of antirust coverage over all of baseball, the Act simultaneously denies such coverage to anything “that do[es] not directly relate to or affect employment of major league baseball players…”[11] This is why the exemption is able to continue protecting the sport’s restrictive relocation rules.

Moving forward, there are some solutions that could potentially help lift this barrier to make it easier for teams to relocate to larger markets and thereby improve their ability to compete. One answer may be for the Supreme Court to remove the exemption themselves.[12] The Court is unlikely to do this because their decision would be retroactive and would leave the MLB vulnerable to numerous lawsuits due to potential anticompetitive actions under the exemption.[13] As an alternative, Congress can enact a law that removes the exemption and applies only it prospectively.[14] Regardless of their obstacles, small-market, low revenue teams like the Milwaukee Brewers, Tampa Bay Rays, and Cleveland Guardians serve as shining examples of low-revenue teams that still find ways to win.[15] To reiterate, the Dodgers and similar large-market teams did not ruin baseball, but the solution to a more equitable league may continue to lie in removing baseball’s antitrust exemption.

Jack Ross is a Second Year Law Student at the Benjamin N. Cardozo School of Law and a Staff Editor at the Cardozo Arts & Entertainment Law Journal. Jack is an avid sports fan and is a supporter of the New York Yankees.

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[1] Dave Roberts On Dodgers ‘Ruining Baseball’ Boast: ‘That Was My Dig’, Fox Sports (Oct. 23, 2025), https://www.foxsports.com/stories/mlb/dodgers-manager-dave-roberts-blue-jays-theyre-very-similar-our-club [phttps://perma.cc/E8U4-GPV5].

[2]Anthony Castrovince, Dodgers rally for repeat, taking captivating Series on dramatic late HRs, MLB (Nov. 2, 2025),  https://www.mlb.com/news/dodgers-win-2025-world-series [https://perma.cc/DPH5-XGG3].

[3] MLB Team Salary Payroll Tracker Spotrac (2026), https://www.spotrac.com/mlb/payroll [https://perma.cc/BE2N-GCFX]; Most MLB Teams Playoff Wins Last 10 Years, Statmuse (2025), https://www.statmuse.com/mlb/ask/most-mlb-teams-playoff-wins-last-10-years [https://perma.cc/T7DG-GDUX].

[4] Tyler Hoguet, Baseball’s Antitrust Exemption, Reg. Rev. (Jun. 26, 2024), https://www.theregreview.org/2024/06/26/hoguet-baseballs-antitrust exemption/#:~:text=Under%20current%20MLB%20rules%2C%2023,2.5%20million%20all%20have%20teams. [https://perma.cc/P96F-JPCV].

[5] Id.

[6] Fed. Baseball Club, Inc. v. Nat’l. League of Pro. Baseball Clubs, 259 U.S. 200, 209 (1922).

[7] Id.

[8] Edward Martin, IV, A Century of Turmoil: Examining the Modern Effects of MLB’s Antitrust Exemption on Labor Relations in Major and Minor League Baseball, 61 Hous. L. Rev. 1025, 1030-31 (2024)

[9] Curt Flood Act of 1998, 15 U.S.C. § 27(a).

[10] Id.

[11] 15 U.S.C. § 27(b)(a).

[12] Marc Normandin, The A’s relocation and MLB’s antitrust exemption won’t fit together, Patreon (Jun. 12, 2023) https://www.marcnormandin.com/2023/06/12/the-as-relocation-and-mlbs-antitrust-exemption-dont-fit-together/ [https://perma.cc/ZN7G-BJXW]

[13] Id.

[14] Id.

[15] Jeff Passan, MLB labor: How fight over salary cap will shape negotiations, ESPN (Sep. 18, 2025), https://www.espn.com/mlb/story/_/id/46294140/mlb-labor-negotiations-salary-cap-baseball-talks-2027-season-lockout [https://perma.cc/6C7B-AN4E]