Kansas City Royals v. Major League Baseball Players Association
United States Court of Appeals for the Eighth Circuit
532 F.2d 615 (1976)
Major League Baseball's 1968 Basic Agreement between the owners and the Players Association (defendant) created an arbitration process for player grievances, later modified in 1970 to use a three-judge panel instead of the Commissioner and to exclude two additional categories of disputes - but grievances about the reserve system, which let teams control players, were never on that excluded list. The 1970 agreement's Article XIV did separately state that the agreement 'does not deal with' the reserve system and that neither side would take concerted action or be obligated to negotiate over it, yet throughout the 1970 agreement's term, multiple players filed reserve-system grievances that the owners never opposed. When the 1973 agreement carried Article XIV forward as Article XV while also modifying aspects of the reserve system, players including Messersmith of the Kansas City Royals (plaintiff) filed grievances that an arbitration panel decided in the players' favor; the district court affirmed the award, and the Royals appealed.
Whether the specific terms of a contract's arbitration clause will be enforced absent forceful evidence that the parties meant to exclude particular grievances from arbitration.