The Greatest Baseball Player to be Sued On His Contract

Sportslaw History: The Greatest Baseball Player

To be Sued For Breach of Contract

Lajoie Case paved payment restrictions until the mid-1970s

When the new American League began operations at the turn of the century, it sought to sign star ballplayers from their National League teams. Second baseman Napoleon ("Nap") Lajoie, unhappy at his capped $2400 per year salary (yes, baseball had a salary cap at the time!) and his restrictive contract conditions, signed with the Philadelphia Athletics of the American League. Lajoie's National League team, incensed that he would flee to a rival, brought a lawsuit in a Philadelphia court, sought to prevent him from playing for the Athletics.

Contract law dictates that one cannot be forced to perform a contract against his will, so the National League team did the next best thing: it asked for an injunction to stop him from going to a rival. To get such a remedy, the team had to prove that Lajoie was "unique and extraordinary" and that a calculation of money as damage would be difficult or inadequate to compensate the team.

Nap Lajoie fits the standard. Probably the best second baseman of his time, he was the first second baseman inducted to the Hall of Fame with a lifetime batting average of .339 over a 21-year career. Lajoie won the American League triple crown after the 1901 season, batting .426, producing 125 RBIs and 14 Home Runs.

Lajoie argued that his contract with the old team was so one-sided (due to the limitation of salary and the of lack of what we now know as free agency) as to be "lacking in mutuality" because the player's obligation could be of indefinite duration while the team could fire a player at any time during the contract with as little as ten days notice.

Although prior cases tended to deny such drastic relief to ballplayers, the Pennsylvania Supreme Court, in Philadelphia Ball Club v. Lajoie, upheld the injunction against Lajoie. "Freedom of contract covers a wide range of obligation and duty between the parties and it may not be impaired so long as the bounds of reasonableness and fairness are not transgressed," wrote the court. Given the "valuable" salary Lajoie received, the court ruled that the agreement was fundamentally fair. Also, his contract had one advantage from most player contracts at the time -- a specified right by the team to renew for the 1901, 1902 and 1903 seasons. This added "advantage" for the player was an indication of how unique a ball player he was considered. But, as Ty Cobb remarked, the type of agreement was "as smooth as goose grease, and few players understood the number of rights they signed away."

Ironically, the injunction did not bring Lajoie back to the National League. The A's traded Lajoie to their Cleveland counterpart (which guaranteed him $25,000 for three seasons) and the Ohio courts refused to enforce the injunction granted by the Pennsylvania court. The only problem was that Lajoie could not set foot in Pennsylvania to play any games in Philadelphia. He never did. Rumor has it that he went to Atlantic City instead.

Nap Lajoie's 1902 dispute added one footnote to his glorious career: it made him the greatest baseball player to be taken to court over a contract dispute. And it solidified the salary structure that would remain in the game until 1975.