commerce was nevertheless irrelevant". Some judges upholding Flood have said they do so reluctantly, only out of duty to precedent, and have criticized it themselves. In Crist, after calling Toolson "shaky" and questioning its divination of Congressional intent from its inaction, Judge Tjoflat called the Court's "beneath that consistency is a layer of inconsistency" defense of the baseball exemption in Flood "puzzling ... [T]he reasoning behind the present rule seems to be a rigid notion of stare decisis, coupled with a hesitancy to render a decision that would operate prospectively only." Of particular contention to scholars is the Court's assertion that Congress would undo baseball's antitrust exemption. Citing their previous inaction, Abrams argues that Congress had sufficiently demonstrated its refusal to act, leaving the matter to the Courts. William Basil Tsimpris has contrasted the application of stare decisis in Flood with the Court's ruling in Helvering v. Hallock, in which it was stated that Congress was unlikely to take action on a precedent, giving the Court the burden of self-correction. For McDonald, the decision to leave baseball's antitrust status to Congress was a poor interpretation of Federal Baseball, as Holmes never specified that legislation was the only pathway to undo his ruling. Section I In attempting to understand why MLB repeatedly enjoyed antitrust exemptions not afforded to other sports, scholars have largely targeted baseball's romantic reputation in American culture, as exemplified by Floods Section I. Abrams wrote that Blackmun "may have confused the business of baseball with the glorious game of baseball, thus explaining the sentimentality of Section I, which has been criticized as "rambling and syrupy", "juvenile", and even "bizarre". Savanna Nolan observed that even "the more serious elements of the opinion have a touch of ridiculousness" due to Blackmun's feelings towards the sport. Abrams also argued that Blackmun had likely used Lawrence Ritter's 1966 book The Glory of Their Times as his primary source, and showed how the careers of many of the players Blackmun listed had been impacted, often adversely, by the reserve system. Stephen Ross takes a slightly more positive view, justifying Section I as a means "to establish the unique role that baseball plays in American culture", but nevertheless rationalizes that romantic picture influenced the Court's decision to exempt baseball from other business rules. Another commentator, Paul Campos of the University of Colorado Law School, has defended it as a "trace of resistance to the