SAN FRANCISCO (CN) – A labor dispute between minor-league baseball players and Major League Baseball may be adjudicated in California, but only for claims against the Pittsburgh Pirates, the Detroit Tigers and the New York Yankees, a federal judge ruled on Wednesday.
In a putative class action, lead plaintiff Aaron Senne – who played for the Miami Marlins organization from 2010 to 2013 – claims Major League Baseball underpays its amateur players.
He originally sued three Major League clubs, Major League Baseball and its commissioner Bud Selig in 2014, eventually adding all 30 Major League teams as defendants.
Ten of those teams moved to dismiss the action, claiming they were not subject to jurisdiction in California. The teams that sought dismissal included the Atlanta Braves, the Boston Red Sox, the Chicago White Sox, the Detroit Tigers, the New York Yankees, the Philadelphia Phillies, the Pittsburgh Pirates, the Tampa Bay Rays, the Washington Nationals and the Baltimore Orioles.
The teams argued that intermittent travel, communications and various other activities in California were not sufficient to establish personal jurisdiction there.
But the minor-league players argued that the Major League has “deep roots in California” and derives “substantial income” from the state.
The players also argued that the “highly interdependent nature” of the Major League supports general jurisdiction, especially because the case involves “a universal scheme enacted by all defendants to depress salaries.”
In the court’s 105-page ruling issued Wednesday, U.S District Judge Joseph Spero said that the Supreme Court’s recent guidance on the theory of general jurisdiction “has made clear that the concept of ‘home’ in the context of general jurisdiction should be understood narrowly.”
He said that despite the MLB’s lucrative licensing deals, “California cannot be considered home to any of these clubs,” because their travel, business and scouting activities in the state “do not represent such a significant portion of their activities that their presence in California would be analogous to being domiciled in California or having their principal place of business in California.”
For that reason, Spero said, there is no general jurisdiction of the teams in California.
He did find, however, that specific jurisdiction in California applies to the Pirates, the Tigers and the Yankees, since the named plaintiffs asserting claims against those teams all reside in the Golden State and have performed offseason work there over the past several years.
Spero dismissed the claims brought against the other seven teams for lack of personal jurisdiction.
Neither side could be reached for comment on Wednesday.
The plaintiffs are represented by Daniel Warshaw, with Pearson Simon in Sherman Oaks, Calif.
The defendants are represented by Elise Bloom, with Proskauer Rose in New York City.
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