One Man Out: Curt Flood Versus Baseball

When Curt Flood, all-star center fielder for the St. Louis Cardinals, refused to be traded to the Philadelphia Phillies in 1968, he sent shock waves throughout professional baseball that ultimately reached the Supreme Court. Flood challenged the game's reserve clause system that bound players to teams as if they were property; and while others had previously spoken out against this arrangement, protected by Congress and the courts for a century, he was the first to pursue his grievance as doggedly or as far.

Robert Goldman now offers a new look at Flood's efforts to shake the foundations of major league baseball. One Man Out takes readers back to the pre-steroid era when baseball was as much a passion as a pastime-and when race was often still a factor-to focus on decisions made in the courtrooms rather than the dugouts.

Flood claimed that the prevailing system was illegal because it violated the Sherman antitrust laws by allowing teams to monopolize the sport in a way that impeded players' freedom and financial gain-and was even unconstitutional because it, in effect, imposed a form of slavery. Baseball owners countered that players owed their success to the reserve system because it maintained competitive balance among teams and heightened interest in the game, which helped fund their high salaries.

Although the Supreme Court ruled against Flood, it left the door open to legislation that would remove baseball's special exemption from antitrust regulation and to future collective bargaining. With its credibility enhanced, the players' union continued negotiations until it finally won a version of free agency very similar to Flood's, with his final vindication coming in the form of the Curt Flood Act of 1998.

In replaying the confrontation between Flood and baseball commissioner Bowie Kuhn, Goldman demonstrates that even a lost lawsuit, with its game-like competition, can be a landmark. And by telling the inside story of the case, he highlights a key labor relations issue in America's most popular sport. Concise and balanced, and written in a fast-paced narrative style, One Man Out reminds students, general readers, and fans that Flood holds a unique and important place in both baseball and American law.

Robert M. Goldman is a professor of history in Richmond, Virginia, and an avid baseball fan. He is the author of Reconstruction and Black Suffrage and "A Free Ballot and a Fair Court": The Department of Justice and the Enforcement of Voting Rights in the South, 1877-1893.