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In MLB, Curt Flood of the St. Louis Cardinals in 1969 and Andy Messersmith of the Los Angeles Dodgers in 1975.

In 1969, there was no free agency in any American sport.

Immediately following the 1969 season, Curt Flood was traded by the Cardinals to the Philadelphia Phillies. He refused to report to the Phillies and in a letter to then Commissioner Bowie Kuhn stated that while the Phillies had tendered a contract offer to him, since he was not under contract to any team that he should be allowed to contact other teams to see if they would be interested in having him play for them. This, by the day's standards, was impossible due to what was known as the reserve clause. The reserve clause was a standard paragraph in every player's contract that stated the team reserved the right to the player's services once the player's contract expired. The reserve clause made free agency impossible. Commissioner Kuhn told Flood he could not become a free agent due to the reserve clause that was in the contract he signed, the contract that had since expired.

Flood filed a lawsuit against Kuhn and Major League Baseball in early 1970 alleging that the reserve clause violated Federal Antitrust Laws concerning wage negotiation and freedom to move from one employer to another. The case eventually went to the U.S. Supreme Court where the court, expectedly, ruled in favor of MLB.

While this ruling was a blow to the players, it did not stop them from continuing to push for free agency.

Finally in 1975 Messersmith, a pitcher, and the Dodgers could not agree on a contract. He played the 1975 season without a contract, by means of the reserve clause that the team held over him. All Messersmith did in the 1975 season was win 19 games, lead the National League in starts (40), innings pitched (321 2/3), and complete games (19). He was selected to the All-Star team and awarded a Gold Glove.

Messersmith filed a grievance over the issue that went to arbitration. In late 1975, a Federal arbitrator ruled in favor of the grievance and that Messersmith was free to negotiate with other teams because a team could not reserve a player's services indefinitely without a contract.

The reserve clause was dead and free agency was born.

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