had conspired to exclude the plaintiffs' clients from the many theaters they controlled in order to extract large payments to them, arguing that since their productions depended on the interstate transport of sets and costumes, the vaudeville circuit was interestate commerce. It had been filed before Federal Baseball; afterwards, the defendants had argued that their industry, too, was similarly not interstate commerce since its main business activity was selling admission to performances it had arranged rather than transport of goods for sale, with the shipments of materials required for those productions merely an incident to their business, just as with baseball teams' travel. The Southern District of New York agreed and dismissed the case. Justice Holmes wrote for a unanimous Court that reversed the trial court on jurisdictional grounds, holding that a federal question existed over whether the vaudeville circuit was interstate commerce, and that until that question was resolved the case was not to be disposed even if the arguments for federal jurisdiction themselves seemed weak. "[I]t may be that what in general is incidental, in some instances may rise to a magnitude that requires it to be considered independently", Holmes wrote. Gardella v. Chandler The case that came closest to overturning the reserve system and antitrust exemption was brought by Danny Gardella, who left the New York Giants in 1946 to play for the Azules de Veracruz of the Mexican League. He returned to New York in 1947 to play in MLB again but found himself blacklisted. Gardella's attorney Frederic Johnson tried to distinguish his client from Nap Lajoie by arguing his client was not an exceptional player or "unique performer", but a standard-quality professional athlete being denied an opportunity to make a living. Judge Henry W. Goddard of the Southern District of New York ruled in favor of the owners, dismissing Gardella's lawsuit under the precedent set by Federal Baseball, The United States Court of Appeals for the Second Circuit overturned this decision, however, with Jerome Frank ruling that baseball's television and radio presence made it a matter of interstate commerce that thus fell under the Sherman Act. The case never reached the Supreme Court, as Happy Chandler, then the Commissioner of Baseball, soon reinstated the blacklisted Mexican League players. Gardella settled out of court for $60,000 in damages and a trade to the St. Louis Cardinals. With Gardella's case settled, there was little pressure on the