University of St. Thomas Law Journal

Scouting Report for MLB’s Next Labor Battle: Lessons To Learn from Baseball’s Past as the Collective Bargaining Agreement Expires

Robert Defren*

When first pitch crossed home plate to inaugurate the 2026 Major League Baseball season, more viewers tuned in to watch the New York Yankees play against the San Francisco Giants than any previous opening-day game.1 The game featured Logan Webb, an All-Star pitcher who signed a five-year $90 million contract in 2024,2 against Aaron Judge, a perennial Most Valuable Player candidate who inked a nine-year $360 million contract in 2023.3 During the previous season, the Giants generated $491 million in revenue, while the Yankees earned the second-highest revenue in the Majors at $755 million.4 In 2016, the average value of a MLB team was $1.3 billion.5 In 2026, that number skyrocketed to an average value of $2.9 billion.6 However, despite the viewership, salaries, revenue, and team values, MLB may not play a single game in 2027.7

The league’s current collective bargaining agreement (CBA), a monumental 426-page labor contract that covers everything from disciplinary hearings to salary arbitration and grievance procedures, is set to expire on December 1, 2026.8 Negotiations preceding the 2022 CBA resulted in a brief work-stoppage that delayed the start of the regular season, but ultimately resulted in teams playing their full-slate of games.9 MLB insiders, however, fear that negotiations after the current CBA’s expiration could result in a prolonged lockout.10 With fears swirling, MLB fans are reminded of the 1994–95 lockout;11 a baseball catastrophe where neither a future Supreme Court justice nor the President of the United States could prevent the cancellation of a World Series.12 This Blog briefly explores the background of MLB labor relations, with particular focus on how the 1994–95 lockout could forecast the upcoming renegotiation.

MLB’s current labor landscape is rooted in a trio of Supreme Court cases. Baseball originated in the mid-nineteenth century.13 By the end of the century, players jumped from team to team on one-year contracts, riding the carousel to whichever club would give them a spot and pay the most.14 In 1887, incensed team owners responded by forming a cartel to restrict player movement.15 The owners’ new weapon was the “reserve clause,” which perpetually bound players to their original teams, through a “contractual hall of mirrors, with endlessly repeating obligations and no reasonable way out.”16 When players began flocking to smaller leagues which banned reserve clauses, the National League ruthlessly bought out the leagues, dissolving teams or absorbing them into the fold.17 This practice culminated in the antitrust suit Federal Baseball Club v. National League, where the owner of the Baltimore Terrapins in the small Federal League alleged a conspiracy amongst National League teams to monopolize the sport of baseball.18 In siding with the National League, the Supreme Court held that baseball falls outside the constraints of the Sherman Antitrust Act.19 Justice Holmes stated that because travel was incidental to playing a singular baseball game, the National League was not involved in interstate commerce despite being a congregation of teams from several states.20 The Supreme Court upheld their ruling in Toolson v. New York Yankees, a decision that rested more on deferring to Congress’s choice not to articulate that baseball fell within the scope of antitrust laws.21 In 1972, the Supreme Court in Flood v. Kuhn finally admitted that MLB operated in interstate commerce.22 Regardless, the Court still held that baseball was not constrained by antitrust laws, recognizing that it was an “aberration” that is “fully entitled to the benefit of stare decisis … on a recognition and an acceptance of baseball’s unique characteristics and needs.”23

Unable to rely on antitrust litigation, players unions became increasingly stronger, leading to the MLB Players Association’s first collective bargaining agreement with the owners in 1968.24 In 1994, the CBA between the owners and players was set to expire.25 Mistrust between the players and the owners was rampant before the expiration.26 Through the 80s and into the 90s, the MLBPA submitted grievances that owners were colluding to not sign free agents to keep salaries down.27 Additionally, baseball had been without a commissioner since 1992, when Commissioner Vincent was voted out by owners.28 In their preliminary negotiations for the new CBA, citing decreasing revenues and difficulties faced by small-market teams, the owners proposed an end to salary arbitration and a league-wide salary cap.29 The players rejected the owners’ proposal.30 As the 1994 season continued, both sides continued playing hardball. The owners refused to budge on their demands for a salary cap, and the players responded by walking out in the middle of the season on August 12, 1994.31 The antitrust exemption severely limited the players’ options during the offseason through litigation, meaning that their only real bargaining power came by striking mid-season32. After months of hopeless negotiation, on September 13, 1994, the World Series was cancelled for the only time since World War II.33

As the lockout continued into the winter, President Clinton became involved and appointed former Department of Labor Secretary W.J. Usery to mediate an end to the impasse.34 However, despite a deadline set by the President, both sides failed to reach an agreement.35 By early 1995, the owners threatened to start the season without players from the MLBPA, instead using “replacement players,” which consisted of minor leaguers, retired big leaguers, and amateurs.36 On March 31, 1995, in a case brought by the National Labor Relations Board (NLRB) alleging unfair labor practices, United States District Court Judge Sonia Sotomayor granted an injunction restoring labor conditions under the expired CBA.37 On April 2, two days before the season was set to begin, the players announced an official end to the strike.38

To avoid a catastrophe like the 1994–95 lockout in 2027, players and owners need to recognize that hardball tactics, which purport to bolster each sides chances of “winning” only lead to the other side becoming more afraid of being the side seen as “losing.” That being said, so long as MLB is exempt from punitive antitrust legislation, the players have the most bargaining power when they refuse to play games. Hopefully, players and owners have learned that to thrive, each side needs to negotiate with the best interest of both parties in mind. As 1994 showed, when each side treats compromise as defeat, the game itself ends up losing.

* Robert Defren, J.D. Candidate, University of St. Thomas School of Law Class of 2027 (Associate Editor).

  1. NBC Sports Delivers Largest MLB Opening Day Audience on Record for Multi-Game Presentation, NBC Sports (Mar. 30, 2026), https://www.nbcsports.com/pressbox/press-releases/nbc-sports-delivers-largest-mlb-opening-day-audience-on-record-for-multi-game-presentation [https://perma.cc/YB6X-3ZYG]. ↩︎
  2. Logan Webb, Spotrac, https://www.spotrac.com/mlb/player/_/id/28182/logan-webb [https://perma.cc/F8GK-ZU6K] (last visited Apr. 15, 2026). ↩︎
  3. Aaron Judge, Spotrac, https://www.spotrac.com/mlb/player/_/id/18499/aaron-judge [https://perma.cc/LYZ7-5D7U] (last visited Apr. 15, 2026). ↩︎
  4. Michael Ozanian, CNBC’s Official MLB Team Valuations 2026: Here’s How the 30 Franchises Stack Up, CNBC (Apr. 7, 2026, 09:31 ET), https://www.cnbc.com/2026/03/13/cnbcs-official-mlb-team-valuations-2026-how-30-franchises-stack-up.html [https://perma.cc/G7Z4-B6JC]. ↩︎
  5. Michael Ozanian, Baseball’s Most Valuable Teams 2016, Forbes (Mar. 23, 2016, 08:42 ET), https://www.forbes.com/sites/mikeozanian/2016/03/23/baseballs-most-valuable-teams/ [https://perma.cc/9QKQ-R5Q8]. ↩︎
  6. Justin Teitelbaum, Baseball’s Most Valuable Teams 2026, Forbes (Mar. 20, 2026, 06:30 ET), https://www.forbes.com/sites/justinteitelbaum/2026/03/20/baseballs-most-valuable-teams-2026/ [https://perma.cc/MBH4-2YCZ]. ↩︎
  7. Maddie Lee, MLB Players Association Bracing for Lockout Before 2027 Season: “All but Guaranteed’, Chicago Sun Times (Feb. 18, 2026, 19:23 CT), https://chicago.suntimes.com/cubs/2026/02/18/mlb-players-association-bracing-for-lockout-before-2027-season-all-but-guaranteed-bruce-meyer-executive-director [https://perma.cc/85QR-KTPB]; Alden Gonzalez, Jeff Passan & Jesse Rogers, What You Need to Know About MLB’s Looming Labor Battle, ESPN (Dec. 1, 2025, 07:00 ET), https://www.espn.com/mlb/story/_/id/47108752/mlb-labor-battle-cba-salary-cap-owners-players-union-mlbpa-faq-manfred [https://perma.cc/S5XV-9463]. ↩︎
  8. Major League Baseball Players Assoc., 2022–2026 Basic Agreement (2022), https://registrationz.mlbpa.org/pdf/MLB%20Basic%20Agreement%202022-26.pdf [https://perma.cc/8NYC-TC4L]. ↩︎
  9. Mark Feinsand, MLB, MLBPA Agree to New CBA; Season to Start April 7, MLB.com (Mar. 10, 2022), https://www.mlb.com/news/mlb-mlbpa-agree-to-cba [https://perma.cc/NGE8-EWPK]. ↩︎
  10. Lee, supra note 7; Gonzalez, Passan & Rogers, supra note 7. ↩︎
  11. Gonzalez, Passan & Rogers, supra note 7. ↩︎
  12. Marc Chalpin, It Ain’t over ‘Til It’s Over: The Century Long Conflict Between the Owners and the Players in Major League Baseball, 60 Alb. L. Rev. 205, 226 (1996). ↩︎
  13. Id. at 207. ↩︎
  14. See Flood v. Kuhn, 407 U.S. 258, 261–64 (1972) (discussing the early years of professional baseball). ↩︎
  15. Garrett R. Broshuis, Touching Baseball’s Untouchables: The Effects of Collective Bargaining on Minor League Baseball Players, 4 Harv. J. Sports & Ent. L. 51, 65 (2013); Ed Edmonds, At the Brink of Free Agency: Creating the Foundation for the Messersmith-McNally Decision-1968-1975, 34 S. ILL. U. L.J. 565, 568 (2010). ↩︎
  16. Broshuis, supra note 15, at 66. ↩︎
  17. Edmonds, supra note 15, at 569–71; L. 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, 1029 (2024). ↩︎
  18. Fed. Baseball Club of Balt., Inc. v. Nat’l League of Pro. Baseball Clubs, 259 U.S. 200, 207 (1922). ↩︎
  19. Id. at 208–09. ↩︎
  20. Id. ↩︎
  21. See Toolson v. N.Y. Yankees, Inc., 346 U.S. 356, 357 (1953) (holding “if there are evils in this field which now warrant application to it of the antitrust laws it should be by legislation.”). ↩︎
  22. 407 U.S. 258, 282 (1972). ↩︎
  23. Id. at 282–83 (Explaining that baseball is such an anomaly that even “[o]ther professional sports operating interstate—football, boxing, basketball, and, presumably, hockey and golf—are not so exempt.”). ↩︎
  24. Broshuis supra note 15, at 70. ↩︎
  25. Chalpin, supra note 12, at 224. ↩︎
  26. Dayn Perry, 1994 MLB Strike 20th Anniversary: Who Was to Blame?, CBS Sports (Aug. 11, 2014, 07:57 ET), https://www.cbssports.com/mlb/news/1994-mlb-strike-20th-anniversary-who-was-to-blame/ [https://perma.cc/2K3B-X2XU]. ↩︎
  27. Murray Chass, Baseball; Players Said to Hit Collusion Jackpot, N.Y. Times(Nov. 4, 1990), https://www.nytimes.com/1990/11/04/sports/baseball-players-said-to-hit-collusion-jackpot.html [https://perma.cc/7WAZ-K98M]. ↩︎
  28. Chalpin, supra note 12, at 226. ↩︎
  29. Chalpin, supra note 12, at 224–25. ↩︎
  30. Id. ↩︎
  31. Id. ↩︎
  32. Id. ↩︎
  33. Id. ↩︎
  34. Id. at 236. ↩︎
  35. Id. ↩︎
  36. Silverman v. Major League Baseball Player Rels. Comm., Inc., 880 F. Supp. 246, 252 (S.D.N.Y.), aff’d, 67 F.3d 1054 (2d Cir. 1995). ↩︎
  37. Id. at 250. ↩︎
  38. Ross Newhan, Baseball Players End Strike; Owners on Deck: Sports: Decision Follows a Judge’s Ruling in Their Favor and Could Pave the Way for an End to the 232-Day Walkout. But Owners May Vote on a Lockout, L.A. Times (Apr. 2, 1995), https://www.latimes.com/archives/la-xpm-1995-04-02-mn-49893-story.html [https://perma.cc/J8XV-VFMC]. ↩︎

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