Last Saturday representatives of the St. Louis Athletic Association made an application to the Superior Court of Hamilton County for an injunction forbidding Tony J. Mullane, of the Toledo Club, from playing base ball with the Toledo Club, on the ground of a violation of contract with the plaintiffs. A temporary restraining order was granted till yesterday, when, upon a hearing, the Superior Court granted an injunction. The defendants to-day carried the matter before Judge Baxter, of the United States Circuit Court, on a motion to dissolve the injunction. The injunctions have been taken out by the St. Louis Club in the State Courts at St. Louis and Cincinnati. The motion to dissolve the injunction against him here was taken before Judge Baxter, on the ground that the petition of the St. Louis Club failed to state facts sufficient to entitle the complainant to the relief prayed for. Judge Baxter heard the arguments of counsel in his private office. He said that he would dissolve the injunction, would give Mullane leave to withdraw from the contract between him and the St. Louis Club, and ordered that this be made a part of the record in the case. Judge Baxter daid he would further give him leave to answer hereafter. In announcing his decision the Judge said he did not think the time of the courts could be occupied by baseball matters. Ball-playing was nothing which benefited the public in any way. It was not a business of any kind, but it was merely a sport, which was beneath the dignity of the courts to notice.-St. Louis Globe-Democrat, May 14, 1884
While I'm not an expert on the subject, I have to imagine that the unique position that Major League Baseball occupies as a legal entity is a result of the attitude expressed by Judge Baxter in 1884. It was sport, rather than business, and it was not a public-benefit. That sort of reasoning, I believe, underpins all of the major legal decisions that involved baseball in the 20th century.