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Seitz decision
Decision ending baseball's reserve clause
Decision ending baseball's reserve clause
The Seitz decision was a ruling by arbitrator Peter Seitz (1905–1983) on December 23, 1975, which declared that Major League Baseball (MLB) players became free agents upon playing one year for their team without a contract, effectively nullifying baseball's reserve clause. The ruling was issued in regard to pitchers Andy Messersmith and Dave McNally.
Background
Since the 1880s, baseball owners had included a paragraph described as the "reserve clause" in every player contract. The paragraph as written allowed teams to renew a contract for a period of one year following the end of a signed contract. Owners asserted and players assumed that contract language effectively meant that a player could be "reserved," by a ballclub's unilateral contract renewal, year after year in perpetuity by the team that had signed the player. That eliminated all market competition and kept salaries relatively low.
The reserve clause was challenged in two Supreme Court cases—Toolson v. New York Yankees, Inc. in 1953 and Flood v. Kuhn in 1972—both of which upheld the reserve clause.
Dave McNally and Andy Messersmith both played professional baseball as starting pitchers. McNally first played professionally in 1961, and made his major-league debut in 1962 with the Baltimore Orioles. Messersmith first played professionally in 1966, and made his major-league debut in 1968 with the California Angels.
Grievance


In 1975, Messersmith played his third season with the Los Angeles Dodgers, The owners disagreed, arguing that under the reserve clause the one-year contracts were perpetually renewed.
The Major League Baseball Players Association (MLBPA) filed notices of grievance on behalf of both players on October 7, 1975. Hearings were held on November 21, November 24, and December 1, before an arbitration panel composed of MLB Player Relations Committee chief negotiator John Gaherin, MLBPA executive director Marvin Miller, and Peter Seitz—the chairman and impartial arbitrator agreed upon by the opposing parties.
Decision
Seitz ruled in favor of Messersmith and McNally on December 23, 1975, declaring:
Seitz's opinion further stated:
In essence, the players were free to bargain with other teams because organized baseball could maintain a player's services for only one year after expiration of the previous contract. According to Gaherin, Seitz indicated soon after he heard arguments from both sides that he was leaning toward ruling for the players.
Aftermath
MLB appealed the decision to the United States district court for Western Missouri, but Seitz's ruling was upheld on February 3, 1976, by Judge John Watkins Oliver, and later by the Eighth Circuit Court of Appeals. In August, after all appeals were exhausted, the league and players' association reached an agreement allowing players with six years of major-league service to become free agents.
McNally and Messersmith were officially granted free agency on March 16, 1976. completing his 12-year major-league career with 344 games pitched (295 starts) and a 130–99 win–loss record. McNally did not play professionally after 1975, having finished his 14-year major-league career with 424 games pitched (396 starts) and a 184–119 record.
References
References
- "Peter Seitz, 78, the Arbitrator in Baseball Free-Agent Case". The New York Times.
- {{ussc. 346. 356. 1953
- {{ussc. 407. 258. 1972
- (October 16, 1975). "McNally, Messersmith Seek Free Agent Status". [[Indiana Gazette]].
- (December 24, 1975). "Baseball bosses irate as Andy awaits bids". [[The Spokesman-Review]].
- [https://law.justia.com/cases/federal/district-courts/FSupp/409/233/2364357/ ''Kansas City Royals Baseball Corp. v. Major League Baseball Players Ass'n, 409 F. Supp. 233, 261 (W.D. Mo. 1976) aff'd, 532 F.2d 615 (8th Cir. 1976)'' – Justia.com.] Retrieved 3 July 2025.
- Chass, Murray. (2000-12-23). "Baseball's Transfer Of Power".
- (February 4, 1976). "Judge upholds ruling". [[Lompoc Record]].
- (August 3, 1976). "Peace reaches baseball". [[The Sun (Lowell).
- "Andy Messersmith Minor Leagues Statistics & History".
- "Andy Messersmith".
- "Dave McNally Minor Leagues Statistics & History".
- "Dave McNally".
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