 When the Newark franchise was dissolved prior to the 1950 season, he was demoted by the Yankees' organization to the Binghamton Triplets, an A-class team within its minor league system.He refused to report and instead filed suit, arguing the reserve clause was a restraint of trade and that baseball should not be exempt from antitrust laws.In 1922, in an opinion by Justice Oliver Wendell Holmes, Jr., a unanimous court held in "Federal Baseball Club" that professional baseball did not meet the definition of interstate commerce under the Constitution and the Sherman Act because, although teams traveled between states from game to game, that travel was "incidental" to the business and not an essential aspect, since all the revenue was generated from the actual games.