Key Findings: First Circuit Partially Revives Antitrust Claims in Puerto Rico Professional Baseball Case


The US Court of Appeals for the First Circuit affirmed the dismissal of federal antitrust claims against a Puerto Rican baseball league in Congrejeros de Santurce Baseball Club, LLC v. Liga de Béisbol Pro. Baseball Clubs (2025 WL 2027882). The court clarified that baseball’s long-standing antitrust exemption is not limited to Major League Baseball but extends to the “business of baseball” as an activity. The court, however, vacated the district court’s dismissal of Puerto Rico state antitrust and fair competition claims, remanding for consideration of whether the Supremacy Clause prevents the application of local laws to the defendants’ conduct.

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