major aspects of his contract, including his salary, were not addressed, and the court decided that the reserve clause was "too indefinite" to be properly enforced. The decision in Metropolitan Exhibition Co. v. Ward also criticized the uneven system by which a team could hold a player theoretically indefinitely but terminate them with only 10 days' notice. This legal victory was not enough to sustain the Players' League, as many of its financial backers pulled out after suffering considerable losses during that premiere season. Hall of Famer Nap Lajoie was taken to court in 1901 by the Philadelphia Phillies, an NL team, after he joined their crosstown AL rival, the Philadelphia Athletics, who were not yet bound by the reserve clause. The Supreme Court of Pennsylvania ruled the next year in Philadelphia Ball Club, Ltd. v. Lajoie that he possessed a unique skill set, much like Johanna Wagner, the defendant in the seminal 1852 English contract law decision Lumley v Wagner. This skill set meant that, while the Phillies could not require Lajoie to play for them, they could prevent him from playing for other teams. Baseball's antitrust exemption The United States Congress had enacted the Sherman Antitrust Act which prohibited the type of anticompetitive collusion under which the reserve clause has been argued to fall, in 1890. This policy was extended even further by the Clayton Antitrust Act of 1914, which allowed private parties to sue for damages caused by anticompetitive conduct. The same year that the Clayton Act became law, the Federal League (FL) was created as a challenger to MLB. Despite the new league prohibiting players from signing if they were under contract with a major league team and MLB threatening to blacklist players who defected, players such as Joe Tinker nonetheless left MLB to join the FL, and many of these defections led to litigation. While the lower courts typically ruled in favor of players who joined the Federal League during the offseason, when they were under reserve but not an active contract, the owners did win some cases where players had abandoned their MLB team midseason. Dave Fultz, the president of the FL, was primarily focused on improving the working conditions of minor league players and improving player safety. He was not radically against the reserve system, and he feared that eliminating it from his league would incur retribution from MLB. Instead, he proposed that