Rose Is in Red, Black Sox Are Blue: A Comparison of Rose v. Giamatti and the 1921 Black Sox Trial

When Cincinnati Reds manager Pete Rose received his banishment from Major League Baseball in 1989, after he was accused of betting on his own team, comparisons were immediately drawn to the Black Sox, the eight members of the White Sox who were banned from the game for allegedly throwing the 1919 World Series in return for payoffs from gamblers. Such comparisons are incomplete without an understanding of the legal settings of both incidents. This Note examines the judicial deference given to decisions of the Commissioner of Baseball and considers such deference in conjunction with Major League Baseball's unique exemption from federal antitrust liability. The author asserts that these factors will probably keep Pete Rose out of baseball and out of the Hall of Fame.