Several of the most important legal documents in the early history of Major League Baseball trace their origins to a protracted legal battle resulting from Napoleon “Nap” Lajoie jumping his contract with the National League’s Philadelphia Phillies to play for the upstart American League Philadelphia Athletics. This move gave the A’s instant credibility as a major league team, and helped foster animosity between the two leagues. The Lajoie case remains relevant in sports law today.
The Pennsylvania State Archives holds a number of documents related to this case. The image shown is of Napoleon Lajoie’s Appeal of the Supreme Court of Pennsylvania’s decision to grant an injunction to prohibit him from playing baseball with any team other the Philadelphia Phillies. It contains Lajoie’s authentic signature. The Archives also holds the State Supreme Court’s decision to reverse the decree of Common Pleas Court No. 5 by granting an injunction in the case of Philadelphia Ball Club (Phillies) vs. Napoleon Lajoie and a Judgment of Non Pros entered by the Supreme Court of Pennsylvania which effectively discontinued the injunction against Lajoie playing baseball for teams other than the Philadelphia Phillies.
After the 1900 baseball season, the newly formed American League declared open war on the National League. The American League renounced baseball’s reserve clause that had bound players to their respective professional teams. Thereafter, bidding wars were fought between the two leagues over players’ services. The National League lost more than 100 of its players to the new American League for the 1901 season. Players switched teams primarily for more money, as the upstart American League paid higher wages. Lajoie was probably the biggest loss for the National League, as he was just reaching his prime and was the most skilled hitter of the day. Nap won the Triple Crown in the American League in 1901, leading the junior circuit in batting average, home runs and runs batted in. His batting average of .426 is the still the highest batting average ever achieved in an American League season.
In early 1901, the owner of the Philadelphia Phillies, Colonel John L. Rogers, filed suit in state court to try to regain Lajoie’s services. Common Pleas Court No. 5 rejected the Phillies request for an injunction against Lajoie and the American League on May 17, 1901. The Phillies promptly appealed this decision.
Two days before the start of the 1902 baseball season, the Supreme Court of Pennsylvania reversed the lower court’s decision and declared that Lajoie should be prohibited from playing for any other professional baseball club other than the Phillies. This decision, filed on April 21, 1902, upheld the reserve clause and the Phillies’ claim to Lajoie. It also established injunctions as a legal remedy to make players honor their contracts.
National League owners hailed the court’s decision as a grand victory for themselves. The American League promised to fight the decision. Connie Mack, president of Philadelphia Ball Club Limited, played Lajoie in the Philadelphia Athletics’ season opener in Baltimore against the Orioles on April 23, 1902. During the game, Mack received a telegram informing him that the Supreme Court had issued an injunction against Lajoie from playing for the Athletics. Mack removed Lajoie from what would end up being his last game as an Athletic for thirteen years.
Napoleon Lajoie appealed the Supreme Court of Pennsylvania’s decision on May 5, 1902. Nevertheless, Lajoie would not play another major league game for any team for about two months, as lawyers and club owners debated what the court’s ruling actually demanded. Eventually, it was decided that the injunction was only effective in Pennsylvania. Not wishing to lose its greatest star in Lajoie, the American League persuaded the Athletics management to transfer Lajoie to the Cleveland franchise. For the remainder of 1902, Lajoie did not even accompany the Cleveland team when it visited Philadelphia, from fear of contempt of court citations or civil lawsuits.
After the 1902 season, the National League was forced to recognize that the American League had become too successful to destroy. Peace was made between the two leagues in early 1903 as the American League agreed to recognize the National Agreement and the reserve clause. Players who had jumped leagues during the “war” of 1901-1902 were allowed to stay with their present teams. The Phillies permitted the injunction against Lajoie to be dismissed by not continuing their action on Jan.5, 1903. Napoleon Lajoie continued his stellar major league career through 1916, amassing more than 3,000 career hits and a lifetime batting average of .338. He was elected to the National Baseball Hall of Fame in 1937.
This edition of Pennsylvania Treasures was written by Richard Saylor, an Archivist at the Pennsylvania State Archives.
About Pennsylvania Treasures:
In early 2012, The Pennsylvania Historical and Museum Commission launched the Collections Advancement Project (CAP), a program to inventory and catalog our vast and significant holdings of art and artifacts. These efforts are resulting in better stewardship of our collections which represent Pennsylvania arts, culture, history, sciences, business and agriculture. As a component of the project, CAP curators have researched rarely exhibited artifacts and works of art. We are sharing these Pennsylvania Treasures with the public through weekly updates.