Milwaukee American Association v. Landis
United States District Court for the Northern District of Illinois
49 F.2d 298 (1931)
The Milwaukee American Association (plaintiff), a minor-league club, sought approval from baseball Commissioner Landis (defendant) for an optional contract to receive a St. Louis Browns player named Bennett, but after Landis learned that the St. Louis and Milwaukee clubs shared common secret ownership by the same individual, he found both clubs had violated the spirit and intent of the Major-Minor League Agreement, absolved Bennett of any obligation to either club, and declared him a free agent. Milwaukee sued, arguing Landis lacked the power to declare Bennett a free agent.
Whether, through agreements with baseball clubs and players, the Commissioner of Baseball is given wide power and discretion to determine whether a specific circumstance or set of facts is detrimental to the national game of baseball.