Labor & Employment Law Daily Wrap Up, DISCRIMINATION—AGE—S.D.N.Y.: MLB defeats claims of systemic age bias in scouting ranks, (Apr 1, 2026)

By George Basharis, J.D.

The court found the former scouts did not plausibly allege a league-wide effort to exclude older workers.

A federal court in New York dismissed an age discrimination suit brought by dozens of former Major League Baseball scouts, concluding that the former scouts failed to allege facts supporting a plausible inference that MLB, its commissioner, and individual clubs collectively engaged in unlawful hiring practices or could be sued together in the forum. The court held that the complaint did not establish personal jurisdiction over most teams and relied on conclusory assertions of coordination and control that failed to establish that age was the determinative factor in hiring decisions. The ruling resolves claims brought by 35 scouts between the ages of 54 and 86 who alleged that MLB and its clubs violated the ADEA by refusing to rehire older scouts following widespread terminations in recent years (Benedict v. Manfred, No. 24-cv-04314 (MMG) (S.D.N.Y. Mar. 26, 2026)).

Systemic age bias. The former scouts alleged that, after being terminated between 2019 and 2022, they were unable to secure new scouting roles despite seeking employment with multiple clubs. The complaint states that none of the scouts was rehired by any MLB team.

The scouts pointed to several individual hiring experiences as evidence of discrimination. In one instance, a scout was told that a team lacked funding to hire additional personnel. In another, a club indicated uncertainty about replacing existing scouts who were “ready to retire.” One scout alleged he was asked directly about his age during an interview and was not hired, while another claimed a team hired a significantly younger candidate without experience instead of him.

Beyond these individual examples, the complaint advanced broader claims of systemic discrimination. It alleged that MLB’s increasing reliance on analytics, often described as a “moneyball” approach, coincided with a shift toward hiring younger scouts and excluding older ones.

The complaint also cited a wave of terminations in 2020, when clubs declined to renew or ended the contracts of older scouts, attributing the decisions to the COVID-19 pandemic. It further alleged that, even after revenues recovered, older scouts continued to be denied opportunities through informal practices and coordinated policies designed to limit their numbers. Additional allegations include the existence of internal lists identifying “Senior Scouts” or other categories of older personnel who were purportedly deemed ineligible for rehire. One scout claimed he was told directly that he appeared on a list of “non-hirable scouts.”

Jurisdiction. The court first addressed whether it could exercise personal jurisdiction over the 28 MLB clubs located outside New York. The former scouts argued that jurisdiction was proper because MLB and its commissioner are based in New York and allegedly acted as joint employers or co-conspirators with the clubs. The court disagreed, finding the complaint failed to establish a sufficient basis to hale the out-of-state teams into a New York forum.

Addressing the scouts’ joint employment claim, the court emphasized that such a relationship requires shared control over the terms and conditions of employment. While the complaint alleged that MLB exercised league-wide authority through standardized contracts, arbitration requirements, and general labor policies, the court found those assertions insufficient.

The complaint did not allege facts showing that MLB controlled hiring decisions, compensation, or day-to-day supervision of any individual scout. Without allegations of “immediate control” over employment decisions, the complaint did not plausibly establish a joint employment relationship. Because the claims were based on an alleged failure to hire, the court further noted that the complaint did not identify any specific club that would have employed a scout under MLB’s direction, nor did it allege facts showing MLB’s involvement in particular hiring decisions.

Conspiracy. The complaint also attempted to establish jurisdiction through allegations of a conspiracy, asserting that the defendants coordinated to limit hiring of scouts over 40. The court held that those allegations did not satisfy the requirements of New York’s long-arm statute. It observed that courts in the district have repeatedly found that the statute does not permit jurisdiction based solely on conclusory allegations without specific facts tying each defendant to actionable conduct in the forum.

In this case, the complaint alleged broad coordination, including agreements to limit hiring and maintain lists of older scouts, but did not provide concrete facts showing how particular nonresident clubs participated in or directed such conduct in New York. As a result, those allegations could not establish a basis for jurisdiction.

Pleading deficiencies. In addition to jurisdictional defects, the court found that the complaint did not meet the required plausibility standard, explaining that a pleading must contain sufficient factual matter to support a reasonable inference of liability. While well-pleaded facts are accepted as true, the court noted that conclusory assertions and speculative allegations are insufficient to sustain a claim.

Applying that standard, the court concluded that the allegations of systemic discrimination relied heavily on generalized assertions about league-wide trends and policies rather than specific, nonconclusory facts linking the defendants to unlawful conduct. The individual hiring examples, the court indicated, did not establish a pattern of discrimination across all defendants, nor did they plausibly show that age was the determinative factor in hiring decisions. Similarly, allegations of blacklists or coordinated policies lacked sufficient detail to move beyond speculation. The complaint did not identify who created or maintained such lists, how they were disseminated, or how they were applied by specific teams.

MLB structure. The court also addressed the structural relationship between MLB and its clubs, which the former scouts argued supported their claims of coordinated conduct. MLB requires scouts to enter standardized employment contracts approved by the commissioner, and league rules prohibit clubs from contacting employees under contract with other teams without authorization. The complaint alleged that these rules, along with compensation offset policies, discouraged mobility and disproportionately harmed older scouts.

The court acknowledged these allegations but found they did not demonstrate unlawful coordination or discriminatory intent. Instead, the policies reflect league-wide governance structures that, without more, do not establish that MLB or the clubs acted jointly to discriminate based on age.

The case is No. 24-cv-04314.

Judge: Garnett, M.

Attorneys: Robert E. Goodman, Jr. (Kilgore and Kilgore) for James S. Benedict. Adam Michael Lupion (Proskauer Rose) for Robert Manfred and The Office of the Commissioner of Baseball dba Major League Baseball.

Companies: The Office of the Commissioner of Baseball; Major League Baseball

Cases: AgeDiscrimination Discrimination Procedure NewYorkNews