they remained bound to their respective teams. Once the reserve system was extended to all players, those players were categorized into five categories under the Brush Classification System, with each group receiving a salary that ranged between $1,500 and $2,500 annually. While the league owners supported the reserve system as a cost-cutting measure, they also defended its use as a way to ensure a competitive balance in baseball. Without a reserve clause, the wealthiest teams could stockpile star players simply by outbidding smaller teams. This sentiment was echoed by federal district court judge William P. Wallace in 1890, who quoted Albert Spalding in arguing that the rule "takes a manager by the throat and compels him to keep his hands off his neighbor's enterprise". The owners also argued that the reserve clause justified a team's investment in its players, who were drafted with little experience and required years of development to reach the major leagues. One of the first players to challenge the reserve clause was Sam Wise, who in 1882 left the Cincinnati Red Stockings of the American Association for the NL's Boston Red Caps. The Massachusetts General Court denied Cincinnati's request for an injunction, and Wise spent the remainder of the season with Boston. The reserve clause's most vocal opponent, however, was John Montgomery Ward, known as Monte Ward, who compared the system to slavery in 1885. In 1890, he helped to found the Players' League (PL), which promised a three-year contract to all players and no pay cuts after the first year. Players' salaries were the same as what the NL had paid them in either 1888 or 1889, whichever was higher. Players who had joined the PL, like Jim O'Rourke, were able to convince their colleagues that the reserve clause only prevented players from joining teams in those leagues that had it, and that they were legally free to join teams in new leagues. When Ward left the New York Giants to join the PL, the team took him to New York Supreme Court to prevent him from playing with his new club. While Justice Morgan J. O'Brien disagreed with Ward and O'Rourke's assessment that the reserve clause did not apply to the Players' League, the court was most concerned about the vague phrasing of the clause: Ward was technically under contract with the Giants for the 1890 season, but the perpetual reserve clause meant that