By Landis Barber
In late March, a federal judge dismissed an age discrimination lawsuit in Benedict, et al. v. Manfred, et al., a case brought by 35 former Major League Baseball (MLB) scouts against the league and its member clubs. The plaintiffs, ranging in age from 54 to 86, alleged that they were pushed out of their roles between 2019 and 2022 and subsequently denied employment across the league. Specifically, each plaintiff sought new scouting opportunities after termination but failed to secure a position with any club.
Throughout the facts, the complaint discussed the evolution of baseball operations. The plaintiffs argued that Major League Baseball’s reliance on analytics, often referred to as “Moneyball,” led to replacing older scouts with younger candidates. Traditionally, scouts evaluated players through in-person observation and qualitative assessments. As alleged, over time, teams began shifting toward data-driven evaluations, video analysis, and statistical modeling. According to the plaintiffs, this transition created a preference for younger scouts.
The plaintiffs further alleged that this shift did not occur naturally. Instead, the shift was a result of coordination among Major League Baseball and its clubs, including the use of informal blacklists and league-level directives designed to limit opportunities for older scouts. Specifically, the plaintiffs referred to alleged lists identifying certain scouts as ineligible for rehire and described communications suggesting that clubs faced pressure to reduce the number of older scouts.
Despite these allegations, the court determined that the plaintiffs’ claims failed. The decision turned less on the merits of age discrimination and more on deficiencies in jurisdiction and pleading. At the motion to dismiss stage, the court evaluated whether the complaint contained sufficient factual allegations to state a plausible claim for relief. For multiple reasons, the court concluded that the plaintiffs failed to meet that standard.
The court first addressed personal jurisdiction. The plaintiffs attempted to bring nearly all Major League Baseball clubs into the Southern District of New York by asserting that MLB operated as a centralized authority, arguing that the league’s headquarters in New York and its role in coordinating certain league-wide policies created a sufficient connection to the forum. The court was not persuaded, emphasizing that jurisdiction requires a concrete connection between the forum and the specific conduct at issue.
Despite teams playing games in New York or maintaining league affiliations, the plaintiffs could not establish a sufficient nexus to alleged hiring decisions affecting individual scouts. Throughout the league, hiring decisions occurred at the club level, often outside New York, and the complaint did not allege that those decisions took place in or were directed from the forum. Without those connections, the court refused to exercise jurisdiction over many of the defendants.
In addition, the plaintiffs argued that Major League Baseball and the clubs acted as a joint employer, collectively controlling employment across the league, making them jointly responsible for hiring decisions. The court disagreed. After examining whether Major League Baseball exercised direct or immediate control over the scouts’ employment, the court determined that the complaint did not support the plaintiffs’ allegations. Instead, the league is a system in which individual clubs hire, manage, and pay scouts. Here, while Major League Baseball may influence league-wide policies, such as standardized contracts, arbitration requirements, and general operating rules, those do not equate to control over hiring decisions. Without that, the plaintiffs failed to establish a joint employer relationship.
Even the claims against the New York-based defendants, the Yankees and the Mets, could not survive dismissal. The Yankees offered a nondiscriminatory explanation for their hiring decision and cited budget limitations. The court accepted that explanation as a legitimate business justification and noted that even profitable organizations routinely make allocation decisions based on internal priorities. A decision not to hire based on financial constraints does not, by itself, support an inference of discrimination.
The Mets did not respond to at least one application submitted by a plaintiff. However, the absence of a response, without more, did not establish discriminatory intent. Employers decline or ignore applications for a variety of reasons. Without additional facts, the claim could not proceed.
Most importantly, the plaintiffs failed to connect the alleged hiring decisions to age discrimination. The complaint did not allege that younger candidates replaced the plaintiffs or that decision makers made age-related comments. It also did not provide comparative examples showing that similarly situated younger applicants received more favorable treatment. Without allegations showing that age played a role, the claims failed to satisfy the pleading standards required under the Age Discrimination in Employment Act.
Courts require more than the possibility of discrimination. When drafting pleadings, plaintiffs must allege facts that make discrimination a plausible explanation for the challenged conduct. Here, the court dismissed the claims because the plaintiffs failed to connect hiring trends to unlawful discrimination. An employer may adopt new strategies, even if those changes disproportionately affect older individuals, so long as age is not the reason for the decision.
By giving the plaintiffs an opportunity to amend the complaint, the court left open the possibility that a more detailed complaint could survive beyond a motion to dismiss. However, any amended complaint will need to provide specific, fact-based allegations that connect individual defendants to acts of discrimination, establish a plausible basis for jurisdiction, and demonstrate that age drove each club’s decision. Based on the opinion, general allegations about industry trends or league-wide practices will not be sufficient.
For practitioners, specificity matters in pleadings. Courts routinely require more than broad allegations that fail to connect the conduct to the claim, and a complaint must clearly articulate who did what, when, and how those actions resulted in discrimination. If a plaintiff fails to draw those connections, the complaint may be dismissed.
Landis Barber is an attorney at Safran Law Offices in Raleigh, North Carolina, where he focuses on civil litigation, construction law, and sports and entertainment matters. He advises clients ranging from universities to private companies on contracts, transactions, and risk management. A member of the Sports Lawyers Association and Vice-Chair of the North Carolina Bar Association’s Sports and Entertainment Section, Landis is licensed to practice in North Carolina, South Carolina, and Tennessee.
