little legal matter. The reserve clause was settled outside the Supreme Court three years later through the arbitration system created by the collective bargaining agreement between MLB and the MLBPA. Peter Seitz ruled in favor of Andy Messersmith and Dave McNally that their contracts could only be renewed without their permission for one season, after which they became free agents. Free agency in MLB was codified the following year after the 1976 Major League Baseball lockout, while the Curt Flood Act of 1998, signed by Bill Clinton, ended baseball's antitrust exemption as it related to interactions between players and owners, but preserved it in other areas such as franchise relocation. Courts have continued to differ over the extent of the exemption; a 2021 suit filed over that year's minor league reorganization asks that it be rescinded entirely. Background Reserve clause William Hulbert, then the president of the National League (NL), instituted the first reserve clause in professional baseball in 1879. Under Hulbert's system, each NL team could "reserve" five players for its roster, and owners from opposing clubs could not offer contracts to reserved players. This provision extended to 11 players per team in 1883, 12 per team in 1885, 14 per team in 1887, and by 1890, all players under active contract with an NL team were subject to the reserve clause. Any player who signed with an NL team was placed under that team's control until they retired, were traded to another club, or were released outright. This latter qualification also made it easier for teams to discipline players by voiding their contracts, and it was sometimes referred to as the "reserve and release" clause. In 1883, the American Association entered into the first national agreement with the NL, extending the reserve system to the Association as well. In 1903, the American League (AL) signed its own national agreement, forming the two-league system known as Major League Baseball (MLB). The reserve clause extended cross-league, with reserved NL players prevented from joining AL teams and vice versa. The primary rationale for instituting the reserve clause was to limit player salaries for the struggling NL by keeping players under team control. Many of the players that the owners reserved for the 1880 season had been, at the time, the best-paid in the league, such as Cap Anson, Paul Hines, and Tommy Bond, and these players saw their salaries drop once