In the 1953 case of Toolson v. New York Yankees, Inc., George Toolson, a minor league baseball player under contract with the New York Yankees organization, challenged Major League Baseball's reserve clause system that restricted players to one team for their career unless traded or sold. He argued this was in violation of federal antitrust laws designed to promote competition and prevent monopolies. The U.S Supreme Court ruled in favor of the defendants (New York Yankees), upholding its previous ruling from Federal Baseball Club v. National League (1922) which stated that professional baseball games were purely state affairs and not subject to federal legislative control as interstate commerce. Therefore, Major League Baseball remained exempt from antitrust laws due to its unique status among professional sports leagues.

In the dissenting opinion for Toolson v. New York Yankees, Inc., Justice Burton argued that the Supreme Court should reevaluate its stance on baseball's exemption from antitrust laws, which was established in Federal Baseball Club of Baltimore v. National League (1922). He pointed out that this precedent had been set at a time when professional baseball was not considered interstate commerce and thus fell outside the purview of federal regulation. However, by 1953, he believed it was clear that professional baseball did indeed constitute interstate commerce due to factors such as radio broadcasting and player trading across state lines. Therefore, he contended that it should be subject to federal antitrust laws like other businesses engaged in interstate commerce. Despite his arguments though, the majority upheld the earlier ruling granting Major League Baseball an exemption from these laws.