“The Cardinal Way” Called into Question

On February 18, 2017, in SELS Blog, by Matthew Weiss

By: Jordan Garnick*

The so-called “Cardinal Way” was considered the method of premier success and class that had kept the St. Louis Cardinals organization relevant from the time of Branch Rickey’s reign over the organization’s front office, all the way into the new millennium.[1] In the late 1920s to early 1930s, Rickey created “the Cardinal Way” through the creation and development of a new concept called “the farm system,” which provided the Major League club in St. Louis with a continual influx of young and talented prospects.[2] Ever since its inception, the “Cardinal Way” of player development and organizational structure has been implemented throughout baseball, and has made the Cardinals the organization that all other baseball clubs strive to become.[3]

However, due to the actions of former scouting director, Chris Correra, the “Cardinal Way” dipped into a dangerous direction that ultimately led to Correra’s imprisonment and the imposition of unprecedented MLB sanctions on the Cardinals franchise.[4]

Per recently unsealed court documents from Correra, as director of scouting for the Cardinals, continually hacked into the Houston Astros’ internal prospect database over 48 times in 2013-14 and hacked into the email accounts of Astros’ director of decision science, Sig Mejda.[5] This act of corporate espionage provided the Cardinals with untold competitive and economic advantages.[6] As implausible as it may seem, neither investigations by the U.S. government nor by the MLB found a co-conspirator to these actions.[7] Thus, Correra was found to have acted in a rogue and evidently purely individual manner.[8] Therefore, Correra ultimately took the biggest hit of all for his actions with a 46-moth prison sentence for pleading guilty to five counts of unauthorized access to protected computer.[9] Additionally, under Commissioner Rob Manfred’s recently announced sanctions against the Cardinals organization, Correra was banned from Major League Baseball for life.[10]

However, Commissioner Manfred still decided to use his power to sanction the Cardinals organization for being vicariously liable for Correra’s actions. Manfred stated “as a matter of M.L.B. policy, I am holding the Cardinals responsible for his conduct.”[11] Thus, he ordered the Cardinals to give up their top two 2017 draft picks (Nos. 56 & 75) and awarded them to the Astros. In addition, the Cardinals were ordered to pay the Astros the sum of $2 million within 30 days of his decision.[12]

While the Cardinals surely will move on after losing their top two picks and $2 million dollars, the stain from these sanctions will remain vivid for the immediate future. The unprecedented nature of Manfred’s ruling illustrates the severity of this situation because no club in baseball’s history has ever had to transfer draft picks to another organization, nor has a club ever been penalized such an amount of money.[13]

These sanctions also demonstrate the MLB’s intolerance for a franchise’s failure to prevent a corrupt director, such as Correra, from emerging within an organization. Comparatively, this ruling seems to somewhat mirror that of the NCAA’s “lack of institutional control,” which assigns liability to universities for the fostering of rogue behavior.[14] While Manfred could have used his discretion to more severely punish the Cardinals, his sanctions were still quite tough. Manfred has now established a precedent for the protection of pertinent intellectual property, which is the type of information technology that MLB franchises currently rely on for scouting.[15] Additionally, even without the imposition of sanctions, a distinguished organization like the Cardinals will consistently have question marks surrounding their future moves and potential success, like that of the ire that has surrounded the New England Patriots’ “deflategate” and “spygate” scandals for the past decade.

The “Cardinal Way” received a noticeable blow after the imposition of these sanctions. While many pundits throughout the sport view Manfred’s ruling as light punishment against the franchise, maybe the ultimate blow to the Cardinals will be how all of Baseball may begin to label the Cardinals as cheaters and no longer see them as the preeminent organization in the National League.[16]

*Staff Writer, Villanova University Sports Law Society Blog; J.D. Candidate, May 2018, Villanova University Charles Widger School of Law.

[1] Tony Calandro, The Cardinal Way: Built to Last, The Huffington Post (Jan. 23, 2014), http://www.huffingtonpost.com/tony-calandro/the-cardinal-way-built-to_b_4164652.html.

[2] Branch Rickey, National Baseball Hall of Fame, http://baseballhall.org/hof/rickey-branch. (last visited February 14, 2017).

[3] See Calandro, supra note 1.

[4] Ben Reiter, As Hacking Scandal Finally Ends, Astros Satisfied with Cardinals’ Penalty, Sports Illustrated (Jan. 31, 2017), http://www.si.com/mlb/2017/01/30/houston-astros-hacking-scandal-st-louis-cardinals-punishment.

[5] Daniel Werly, This Week in Sports Law (1/30): Cardinals Sanctions, The White Bronco, (Jan. 30, 2017), http://thewhitebronco.com/2017/01/this-week-in-sportslaw-130-cardinals-sanctions-tom-benson-trial-approaching-and-trumps-immigration-order/.

[6] Euan McKirdy, Cardinals Fined, Must Give Up Draft Picks After Astros Hacking Scandal, CNN (Jan. 21, 2017), http://edition.cnn.com/2017/01/31/sport/cardinals-mlb-fine-draft-picks-penalty/.

[7] See Reiter, supra note 4.

[8] See id.

[9]Bob Nightengale, Nightengale: For Cardinals, Stain Stings More Than Punishment for Astros Hack, USA Today, (Jan. 30, 2017), http://www.usatoday.com/story/sports/mlb/columnist/bob-nightengale/2017/01/30/mlb-cardinals-astros-hacking-penalty/97260786/.

[10] See id.

[11]Tyler Kepner, Cardinals to Suffer, but Former Executive Bears Brunt in Hacking Case, The New York Times (Jan. 30, 2017), https://www.nytimes.com/2017/01/30/sports/mlb-st-louis-cardinals-hack-houston-astros.html?_r=1.

[12] See id.

[13] See Reiter, supra note 4.

[14] Tom Verducci, Lax Hack Smack: MLB, Rob Manfred Let Cardinals Off Easy in Hacking Scandal, Sports Illustrated, (Jan. 30, 2017), http://www.si.com/mlb/2017/01/30/cardinals-astros-hacking-chris-correa.

[15] See id.

[16] Mark Saxon, Cardinals Get Off Light with Hacking Scandal Penalties, ESPN (Jan. 30, 2017), http://www.espn.com/blog/st-louis-cardinals/post/_/id/2828/cardinals-get-off-light-with-hacking-scandal-penalties.


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