Over Fifty Years Before Jackie Robinson Broke Major League Baseball’s Color Barrier, an Integrated Minor League Team Battled for the Rights to Future Hall of Fame Black Ballplayer Frank Grant

Harrisburg Base-Ball Club v. Athletic Association, 1890 WL 2997, Pa.Com.Pl. (1890)

Who was Frank Grant?
The plaintiff in this case, better known as the Cuban Giants, was admitted to Eastern Interstate League as the representative from York, Pennsylvania and played as the Monarchs.  The manager of the defendant Harrisburg Ponies, James Farrington, was none too pleased that the talented Giants were welcomed into the league and countered by luring second baseman Frank Grant and catcher Clarence Williams to sign on with the Ponies, despite the fact that each had already signed contracts to play for the Giants/Monarchs for the 1890 season.
Grant was held in such high regard that he received a hero’s welcome in Harrisburg and was nicknamed “The Colored Dunlap” (an obviously insensitive moniker nowadays) due to his favorable comparisons to white second baseman Fred Dunlap.
According to the Harrisburg Morning Patriot, Grant was the “most famous colored ballplayer in the business” and “when he appeared on the field a great shout went up from the immense crowd to receive him, in recognition of which he politely raised his cap.”
What was the basis for the lawsuit?
The Giants claimed that the loss of Grant, one of their “most expert players” would cause irreparable harm to their profitability.  Moreover, the Giants claimed that they had expended great sums of money to erect “buildings, fences and accommodations for the public” with the expectation that Grant, “a player of great reputation,” would draw a substantially larger paid attendance.  They asked the court to issue an injunction to prevent Grant from playing for the Harrisburg Ponies in 1890.  Importantly, however, the Giants could not ask the court to compel Grant to play for them in 1890 because such a remedy was not available at law.
So who won?
The court ruled in favor of the Ponies and Frank Grant was allowed to play the 1890 season for Harrisburg.
The court found that because they did not have the power to force Grant to play for the Giants in 1890, Grant’s playing for the Ponies was not the direct cause of the damages to the Giants.  In other words, the Harrisburg Ponies were not at fault because the Giants would have sustained the same claimed losses even if Grant had played a team other than the ponies.
Additionally, the court found that Grant’s contract with the Giants was not fully enforceable because it lacked mutuality, in that only the Giants had the right to compel specific performance.  The provision that the court singled out gave the club the right to cancel the contract “at any time” if it appeared that Grant was “not fulfilling his agreements to the best of his ability.”
What happened after the case was decided?

Grant enjoyed a productive season for the Ponies during their time in the Eastern Interstate League, hitting .333, slugging .488 and stealing 22 bases in 59 games.  In the middle of July, an opportunity arose for the Ponies to join a higher minor league when the Jersey City Jerseys of the Atlantic Association folded. 

The problem for the Ponies was that the American Association did not have any black players.  Teams such as the Washington Senators and Baltimore Orioles initially refused to play the Ponies if Grant was in the lineup.  Regardless, Harrisburg was admitted and took over Jersey City’s record. 

Despite the prejudice Grant faced on and off the field, he hit .332 with 13 doubles in 47 American Association games with the Ponies.  In 2006, Frank Grant was inducted into the Hall of Fame by the Negro League Committee.

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