One of the biggest opportunities for minor league baseball players to further their career is through Spring Training. Spring Training is where minor leaguers compete with and against major league baseball players during the month of March. While the chance to prove themselves at the highest level of the sport is attractive, the pay received by these minor leaguers during this tryout is far from glamorous. Former minor league baseball player and current attorney Garrett Broshius illustrated this problem by stating that “[m]ost fans don’t know [that] those minor league players have to work 31 straight days [with] no pay”[i] when they participate in spring training. These athletes, who are competing with each other to achieve their life-long dreams of becoming professional baseball players, are being forced to work by their employers without even receiving the basic minimum wage to compensate for their time.

For decades, Major League Baseball (MLB) has had the pleasure of exploiting its youngest and most vulnerable players but refusing them a livable wage and stripping them of the basic labor rights they should be provided as employees. The MLB has used improper logic and gray-area loopholes to suppress its employees’ rights, who arguably need the most protection.  The ruling in Senne v. Office of the Commissioner of Baseball and the formal recognition of minor league players who wish to join the Major League Baseball Players Association (MLBPA) are two major steps in getting justice for these minor leaguers.

Senne arose in 2019, and it quickly became one of the largest and most impactful wage-and-hour class action suits in American history. This suit was settled between Major League Baseball and current and former minor league baseball players who felt they had been underpaid and exploited by the MLB. Senne produced a landmark decision that helped minor league baseball players gain fairer wages and more labor protections. This suit arose in 2014 when players sued over alleged violations of the Fair Labor Standards Act and several states’ labor laws.[ii] Minor league players complained that they had been paid “as little as $1,100 a month during a five-month season” and little to no compensation for “essentially mandatory” postseason and off-season activities.[iii]

Senne involved four certified classes of players that represented the states of Arizona, Florida, and California, as each of these states is the primary domain for MLB Spring Training facilities.[iv] The MLB had essentially treated its minor league players like “interns or trainees” who would be exempt from certain labor protections, even though the players were required to “sign seven-year contracts that obligated them to perform services throughout the calendar year.”[v] In March 2022, U.S. Magistrate Judge Joseph C. Spero ruled in favor of the players finding that the “MLB violated state minimum wage laws” and that the MLB would be responsible for “triple damages.”[vi]

The attorney who launched this suit, Garrett Broshuis claimed that “[t]his settlement is a monumental step for minor league players toward a fair and just compensation system.”[vii] Countless minor league baseball players faced the reality of earning poverty-level wages or even less from the MLB while trying to make it as a major leaguer. Forcing these players to work with sub-par conditions while essentially living paycheck to paycheck is an abuse of power by the MLB and could easily be seen as an exploitation of labor.

This ruling from the Northern District of California sent shockwaves throughout the baseball community as it was the first time minor leaguers had gained legal recognition from the MLB. In fact, this ruling has given way for the minor leaguers to be protected by the same bylaws provided to major leaguers through the MLBPA. On September 9, 2022, Major League Baseball Commissioner Rob Manfred notified the MLBPA that the MLB is prepared to recognize the minor league players’ union.[viii]

Throughout professional baseball history, minor leaguers have not had the luxury of being recognized as a legitimate players union. Some have called the recognition of minor league players by the MLBPA as “game-changing” as it gives these players an “enhanced bargaining power and a chance to improve their standard of living.”[ix] Despite the lack of recognition and compensation for their players, minor league baseball clubs are overall a profitable business. On average, “the top [twenty] teams are worth $21.2 million and pulled in $9.8 million in revenue per team.”[x] Compare this to minor league players, where the majority earned between $4,800 and $14,700 annually.[xi]

This compensation at the minor league level is laughable for players pursuing the dream of becoming major leaguers and making upwards of six figures. With an average salary of much less than $20,000 per year, it is almost impossible for these players to further pursue their careers without obtaining a second form of income. For most minor leaguers, this is an unattainable option because the goal of making it to the MLB is a year-round occupation. Players must focus on their physical and mental health for twelve months out of the year if they want a realistic opportunity to make it into the big leagues.

As the revenue generated by the MLB continues to grow, we will continue to see more and more minor leaguers trying to get their respective piece of the pie. While this will take time, the MLBPA must do its part in protecting the players that will eventually make it to the MLB and those who are not as lucky. By acknowledging minor leaguers as legitimate professional baseball players, both the MLB and the MLBPA would be taking a necessary step for the game’s future. Just because an individual plays a “game” or a “sport” for a living does not mean they should not have the same protections as any regular employee. The current state of the MLB and its Minor League affiliates has a lot of growing to do regarding its labor protocol. Despite this, Senne and Commissioner Manfred’s recognition of the minor leaguers is a massive step in reconciling the differences between the league and its players.

[i] Pat Garofalo, The MLB Makes Millions on Minor Leaguers. It Refuses to Pay Minimum Wage., Talk Poverty (Feb. 14, 2019) https://talkpoverty.org/2019/02/14/mlb-makes-millions-minor-leaguers-refuses-pay-minimum-wage/.

[ii] Lauren Berg, MLB, Minor Leaguers Ink $185M ‘Starvation’ Wage Deal, Law360 (July 15, 2022, 11:30 PM) https://www.law360.com/articles/1512283.

[iii] Id.

[iv] See Senne et al v. Office of the Commissioner of Baseball, et al, 105 F. Supp. 3d 981, 992 (N.D. Cal. 2022).

[v] Max Jaeger, Minor Leaguers Ruled MLB Employees In Minimum Wage Suit, Law360 (Mar. 16, 2020, 7:00 PM) https://www.law360.com/articles/1474404/minor-leaguers-ruled-mlb-employees-in-minimum-wage-suit.

[vi] Id.

[vii] Jeff Passan, MLB to pay $185 million in settlement with minor league players over minimum-wage and overtime allegations, ESPN (July 15, 2022) https://www.espn.com/mlb/story/_/id/34249632/mlb-pay-185-million-settlement-minor-league-players-minimum-wage-allegations.

[viii] See Daniel Chavkin, MLB Prepared to Recognize Minor League Players Union, Manfred Says, SI (Sept. 9, 2022) https://www.si.com/mlb/2022/09/09/mlb-prepared-to-recognize-minor-league-players-union-rob-manfred-says-mlbpa.

[ix] Beverly Banks, Minor League Baseball Union is ‘Game Changing,’ Experts Say, Law360 (Sept. 15, 2022, 9:55 PM) https://www.law360.com/articles/1530870/minor-league-baseball-union-is-game-changing-experts-say.

[x] Michael K. Ozanian, Teams for Sale? Minor Leagues, Major Profits- Forbes Sports Valuations, The Sports Advisory Group, https://www.thesportsadvisorygroup.com/resource-library/business-of-sports/minor-leagues-major-profits-forbes-sports-valuations/#:~:text=On%20average%2C%20the%20top%2020,by%20the%20big%20league%20affiliates (last visited Sept. 30, 2022).

[xi] Passan, supra note 6.