the rationale for baseball's exemption had long been that the principles of competition and fair trade, which were key elements of antitrust laws, did not apply to baseball. Baseball thrived only because teams had an even distribution of talent, even though this meant placing restrictions on players' movements from team to team. As Holahan explains, professional sports have been exempt from antitrust laws "because of an important industry characteristic: a good season results only if teams are fairly well matched and play exciting games with uncertain outcomes." The exemption thus allowed a reserve system "for the ostensible purpose of attaining and maintaining league balance" (Holahan 129).
It had been reasoned that clubs in bigger cities could afford the best players and in effect prevent smaller clubs from signing the best players. "In the early days of baseball, players were free to switch teams after the completion of each and every season . . . . Thus, a player could seek out that team which was willing to pay the highest price for his services" (Chelius & Dworkin 539-545). Shortly after the National League was founded (in 1876) a group of officials met in Buffalo, New York, to establish the game's first "reserve rule." At first, the rule was written to protect only five players per team, but by 1890 owners succeeded in having the reserve rule affect every player on the team (Chelius & Dworkin 539-545).
In contradistinction to the notion that the reserve clause, and baseball's exempt status, assured fair team competition and thereby protected the integrity of the game, a new "'theory"' emerged - for the players. As Hoerr explained it, "The players are really entertainers and as such, command a potential market value that can't be calculated with
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