When former New York Giants outfielder Danny Gardella died at age eighty-five on March 6, 2005, the baseball world paid little attention to his passing. But in the late 1940s, Gardella posed a clear and present danger to the baseball establishment when he challenged the game's reserve clause. In 1946, Gardella failed to sign a contract with the Giants and bolted to the Mexican League. Gardella and other major leaguers enticed south of the border by Mexican entrepreneur Jorge Pasquel were blacklisted for five years by Commissioner A. B. "Happy" Chandler and unable to resume their baseball careers in the United States when the Mexican League folded. Denied an opportunity to make a living playing major-league baseball, Gardella sued the sport, arguing that baseball's reserve clause was in restraint of trade and violated antitrust law.
The vitriolic reply of the baseball establishment was to label Gardella a radical threat to the American way of life--as it is embodied in the traditions of the national pastime. Brooklyn Dodgers executive Branch Rickey deserves credit for defying baseball's color line by signing Jackie Robinson, but he was also a staunch anticommunist Republican who interpreted any challenge to management prerogatives as an example of Bolshevism. Speaking in Baltimore on April 13, 1949, Rickey proclaimed that individuals questioning baseball's sacred reserve clause were persons "of avowed communist tendencies who deeply resent the continuance of our national pastime." Commissioner Chandler also employed rhetorical excess in describing the dire consequences the Gardella lawsuit posed to the American way of life. Insisting that he tried to reason with Gardella and others who deserted the United States for Mexico during a time of national crisis, Chandler argued, "I tried to get them to live up to their obligations and responsibilities. This was a fight against baseball in the United States. These players joined a group who said they were going to kill baseball in the United States." (1)
Gardella, of course, was no Bolshevik. He was simply a young man of working-class origins who sought to maintain a job in baseball and obtain a fair salary in return for his labor. Gardella, like many other ballplayers, perceived the sport's reserve clause as limiting his economic options and endangering his livelihood. Therefore, he sued baseball for banning his return to the major leagues after testing the Mexican labor market. Gardella was essentially advocating for a free labor market, while baseball ownership sought to maintain a restricted labor supply. The baseball establishment, however, attempted to portray Gardella as a radical who was challenging traditional American values. The red-baiting employed by Major League Baseball (MLB) was an old tactic going back to nineteenth-century efforts by business to label union organizers as communist agitators. Such rhetoric was even more politically charged during the post--World War II red scare in which feminists, liberals, labor unions, and civil rights activists seeking change and reform were characterized as communist sympathizers undermining the American way of life. Danny Gardella wanted an opportunity to continue playing baseball, but MLB ownership responded to his legal challenge with the rhetoric of the blacklist and postwar anticommunist crusade. Thus, an examination of Gardella's lawsuit against MLB offers insight into the economic structure of the game as well as how business interests sought to use the rhetoric of anticommunism to discredit challenges to monopolistic practices.
A SPORT OR A BUSINESS?
In April 1921, the District of Columbia Court of Appeals ruled that professional baseball was not subject to antitrust law because the sport failed to constitute interstate commerce. The appeals court concluded that although the travel of players from state to state might appear to be interstate commerce, the game of baseball was "local in its beginning and in its end. …