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The Seitz decision was a ruling by arbitration Peter Seitz (1905–1983) on December 23, 1975, which declared that Major League Baseball (MLB) players became upon playing one year for their team without a contract, effectively nullifying baseball's reserve clause. The ruling was issued in regard to pitchers Andy Messersmith and Dave McNally.
The reserve clause was challenged in two Supreme Court cases— Toolson v. New York Yankees, Inc. in 1953 and Flood v. Kuhn in 1972—both of which upheld the reserve clause.
Dave McNally and Andy Messersmith both played professional baseball as . McNally first played professionally in 1961, and made his major-league debut in 1962 with the Baltimore Orioles. Messersmith first played professionally in 1966, and made his major-league debut in 1968 with the California Angels.
The Major League Baseball Players Association (MLBPA) filed notices of grievance on behalf of both players on October 7, 1975. Hearings were held on November 21, November 24, and December 1, before an arbitration panel composed of MLB Player Relations Committee chief negotiator John Gaherin, MLBPA executive director Marvin Miller, and Peter Seitz—the chairman and impartial arbitrator agreed upon by the opposing parties.
Seitz's opinion further stated:
In essence, the players were free to bargain with other teams because organized baseball could maintain a player's services for only one year after expiration of the previous contract. According to Gaherin, Seitz indicated soon after he heard arguments from both sides that he was leaning toward ruling for the players.
McNally and Messersmith were officially granted free agency on March 16, 1976. Messersmith signed with the Atlanta Braves on April 10, 1976, and went on to play in MLB through the 1979 season, completing his 12-year major-league career with 344 games pitched (295 starts) and a 130–99 win–loss record. McNally did not play professionally after 1975, having finished his 14-year major-league career with 424 games pitched (396 starts) and a 184–119 record.
Grievance
In 1975, Messersmith played his third season with the Los Angeles Dodgers, while McNally played his first season with the Montreal Expos, having been traded by the Orioles in December 1974. Both players had had their 1974 contracts automatically renewed by their teams for the 1975 season, on the basis of the reserve clause. Since neither signed a contract during that option year, both asserted that they were free to sign with other teams the following season (1976). The owners disagreed, arguing that under the reserve clause the one-year contracts were perpetually renewed.
Decision
Seitz ruled in favor of Messersmith and McNally on December 23, 1975, declaring: Kansas City Royals Baseball Corp. v. Major League Baseball Players Ass'n, 409 F. Supp. 233, 261 (W.D. Mo. 1976) aff'd, 532 F.2d 615 (8th Cir. 1976) – Justia.com. Retrieved 3 July 2025.
Aftermath
MLB appealed the decision to the United States district court for Western Missouri, but Seitz's ruling was upheld on February 3, 1976, by Judge John Watkins Oliver, and later by the Eighth Circuit Court of Appeals. In August, after all appeals were exhausted, the league and players' association reached an agreement allowing players with six years of major-league service to become .
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