league to alter the reserve system or any other anticompetitive measures. Some members of Congress, however, were worried about the potential challenge to baseball's antitrust exemption, as well as the instability to the sport caused when Chandler was replaced by Ford Frick. In 1951, four bills were introduced to Congress that would have further codified the antitrust laws concerning baseball. Toolson v. New York Yankees, Inc. Congress ultimately took no action on the antitrust exemption, as the House Subcommittee on the Study of Monopoly Power decided that enacting official legislation would affect the Supreme Court's decision on another case that had come its way, Toolson v. New York Yankees, Inc. George Toolson, a minor league player in the Yankees' farm system, had been reassigned from the Newark Bears, their Triple-A affiliate, to the Low-A Binghamton Triplets in 1949. He refused to report to the new club and brought the reserve clause to court as an antitrust violation. In a 7–2 ruling, the Court upheld the Federal Baseball precedent that the "business of giving exhibitions" was "purely state affairs" and thus exempt from the antitrust protections built into the Sherman Act. The one-paragraph per curiam majority opinion in Toolson held that any changes to the Federal Baseball precedent would have to go through Congress and not the courts. Justice Harold Hitz Burton dissented, arguing that organized baseball was obviously engaged in interstate trade and commerce and thus should be subject to federal antitrust enforcement. Shuster and International Boxing The Court did not revisit baseball's antitrust exemption, although other lower courts would. In the years after Toolson, three other antitrust cases involving other industries, including other professional sports, made baseball's exemption problematic when the Court declined to extend the logic of Federal Baseball to them. Early in 1955, two cases decided the same day involved federal Sherman Act cases against companies alleged to have nearly monopolized theatrical performances and professional boxing. Both defendants had argued that the Federal Baseball precedent applied to them as well since the interstate travel required to stage performances and fights was equally incidental to those events, and judges in the Southern District of New York hearing the cases granted defense motions to dismiss. The government appealed directly to the Supreme Court under the Expediting Act. In both cases, the Court allowed the cases to proceed. The theater case, United States v. Shuster, was decided unanimously. After citing