October 2025

The Dark Reality of Family Vlogging: Minnesota’s Legislative Attempt to Combat Child Labor in Content Creation

October 28, 2025
Entertainment Law, Family Law, Social Media

Shayla Miller, MJLST Staffer

Minnesota joins a short list of states to pass specific laws protecting children featured in social media content (“kidfluencers”) from exploitation. Effective July 1st, 2025, through an addition to the Minnesota “Child Labor Standards Act,” lawmakers set out requirements for payment of minors featured in social media content.[1]

The Rise of “Kidfluencers”

Social media content creation has quickly become a lucrative career for many individuals—with over 200 million content creators worldwide.[2] While the number of followers, source of income, and profits made from such creations vary greatly, millions of individuals have taken to social media for work.[3] One particular area that has grown exponentially in recent years is “family vlogging,” or content that features families’ daily lives, including the lives of their children.[4] On its face, this content appears to be harmless, family-friendly, and fun for the children involved. Unfortunately, in many cases, the work of these “kidfluencers” amounts to a new form of child labor, with family members exploiting and overworking young children to make a profit.[5] In addition to children working for no pay, in many cases, children are too young to consent to their personal lives being spread online.[6] Severe cases of child exploitation have sparked major media platforms such as Netflix and Hulu to produce documentaries detailing these particularly horrific cases.[7]

State Legislative Response

As a result of the continued growth of the content creation industry and the increased media scrutiny of “kidfluencers,” several state legislatures, including California and Illinois, have considered the adoption of protective legislation. These statutes often create a minimum threshold for a minor’s presence in a video, as well as a minimum threshold for following/engagement with content, before those minors must be compensated. If a particular account meets the threshold, and a particular minor is present in enough content to meet that threshold, said minor must be compensated for their presence.

In California, a minor is considered to be “engaged in the work of vlogging” if they are in at least thirty percent of the content showcased on an account in one year.[8] Any minor who is considered “engaged in the work of vlogging” on accounts that receive $1,250 a month or more must be compensated for their participation.[9] Their compensation should be proportioned based on the percentage of content they are in, thus if a child is in forty percent of the content for the month, forty percent of the profits should be set aside for them in a trust to be accessed once they reach the age of majority.[10] Illinois and Utah have very similar statutes requiring a trust to be created for “qualifying minors.”[11] The goal of such statutes is to ensure that minors who are engaging in the labor of content creation, and helping to turn profits for the adults running their accounts, are adequately compensated for their time and presence in content.

Most recently, Minnesota added language to the “Child Labor Standards Act” addressing “kidfluencers” by creating a framework for their compensation. Under the new law, a minor is considered “engaged in the work on content creation” if the number of views generated by the content meets the threshold for compensation by the platform and the minor is present in 30% or more of the compensated videos within a thirty-day period.[12] Minors who are deemed to be engaged in content creation must be compensated for their work via a trust created for them by the adult content creator, the structure of compensation being dependent on their age. Children under fourteen who are considered engaged in content creation must be given 100% of the proceeds from any video they appear in.[13] Alternatively, for minors between the ages of fourteen and eighteen, content creators must set aside the percentage of their gross income from a video that corresponds to the percentage of that video that includes the minors’ “likeness, name, or photograph.”[14] The main goal of this addition to the “Child Labor Standards Act” is to address concerns with digital age exploitatio,n including the accessibility and the permanent nature of internet content.[15]

Potential Issues with Current Statutory Structure

While the new statute was a step in a positive direction for protecting minors featured in social media content, there are a few pitfalls that may result in the statute failing to effectuate its intended purpose. These include concerns regarding enforcement and a lack of definition of key terms.

Enforcement Concerns

The new Minnesota statute provides a few different mechanisms for enforcement. First, a minor may commence a civil action against a content creator who fails to provide them with a trust account as required by the statute.[16] Second, the state attorney general may bring an enforcement action against a creator whom they determine is not satisfying the requirements outlined above.[17] While both mechanisms appear useful, practicality questions whether a minor will have the requisite knowledge and impetus to bring an enforcement action against a content creator, particularly given that these content creators tend to be parents or other family members. Similarly, apart from the particularly public cases, query as to whether the attorney general will bring an enforcement action against a content creator without the implicated minor first doing so.

Given the recency of the statute’s passage, it is too soon to tell whether the existence of the statute alone will be sufficient to motivate content creators to compensate minors present in their content without enforcement actions. Should the statute itself fail to change influencers’ behavior, a close look at whether the attorney general or minors themselves utilize the enforcement mechanisms will be instructive as to its effectiveness at stopping the exploitation of minors on social media.

Lack of Definition for “Gross Income”

A second potential issue with the new statute is the lack of definition for “gross income.” Content creators are instructed to pay qualifying minors a percentage of the gross income earned from their videos; however, the additions to the definition section of Minnesota’s Child Labor Standards Act do not include a definition for gross income.[18] Alternate portions of the Minnesota code provide a definition of gross income.[19] However, none adequately cover the vast ways in which content creators are compensated.[20] An addition to the definition section indicating that gross income shall include, but is not limited to, all income from; affiliate marketing, platform payouts, licensing content, monetizing expertise, digital products, and all other social media income sources that may develop, would be useful to effectuate the purpose of ensuring minors are adequately compensated for their presence in social media content.[21] Without a specific definition tailored to the income sources for content creators, it is easy to imagine a reluctant content creator cutting corners by only setting aside income for minors from some of the sources through which they are paid for their online content.

Ultimately, the addition of language to Minnesota’s Child Labor Standards Act addressing child content creators was necessary to ensure the Act keeps up with changes to the child employment space. It provides a great step in the direction of protecting minors from exploitation in the content creation space, but it may need some revision to ensure the statutory scheme is enforceable.

 

Notes

[1] Minn. Stat. § 181A.03 (2025).

[2] Nicholas Bouchard, 40 Creator Economy Statistics You Need to Know in 2025, The Leap (last updated Jan. 29, 2025), https://www.theleap.co/blog/creator-economy-statistics/.

[3] Id.

[4] Communications, Turning Play into Profit: The Dark Reality of Kidfluencing, Ivey (Apr. 29, 2025), https://www.ivey.uwo.ca/impact/read/2025/04/turning-play-into-profit-the-dark-reality-of-kidfluencing/.

[5] Daniel R. Clark & Alisa B. Jno-Charles, The Child Labor in Social Media: Kidfluencers, Ethics of Care, and Exploitation, J. Bus. Ethics 35, 36 (2024).

[6] Ariana Dell, Growing Up in Front of a Camera: The Worrying Trend of Family Influencers Documenting Every Second of Their Children’s Upbringings, Lancaster Univ. (June 10, 2024), https://www.lancaster.ac.uk/richardson-institute/blogs/growing-up-in-front-of-a-camera-the-worrying-trend-of-family-influencers-documenting-every-second-of-their-childrens-upbringings.

[7]Are There Laws About Child Influencers in Minnesota?, White & Assocs. (last accessed Oct. 15, 2025), https://www.whiteandassociateslaw.com/2025/09/30/are-there-laws-about-child-influencers-in-minnesota/.

[8] Cal. Fam. Code § 6651 (Deering 2025).

[9] Id.

[10] Cal. Fam. Code § 6653 (Deering 2025).

[11] See 820 Ill. Comp. Stat. Ann. 206/95 (LexisNexis 2025); see also Utah Code Ann. §34-23-501 (LexisNexis 2025).

[12] Minn. Stat. § 181A.13 (2025).

[13] Id.

[14] Id.

[15] Lincoln Roch, New Minnesota Law Regulates Minors’ Roles in Social Media Content, TCA News Serv., (July 18, 2025), https://www.proquest.com/docview/3231134098?accountid=14586&parentSessionId=JlPr4S9uchgDcvN7A%2BdCHqSf05dj5Rfi6wc04Ot5nP0%3D&sourcetype=Wire%20Feeds.

[16] Minn. Stat. § 181A.13 (2025).

[17] Id.

[18] Minn. Stat. § 181A.03 (2025).

[19] See Minn. R. 9505.0015 (defining gross income as “all earned income before any deduction, disregard, or exclusion”); see also Minn. Stat. § 290.01 (citing to the Internal Revenue Code definition of gross income, which is as follows: “compensation for services, including fees, commissions, fringe benefits, and similar items”).

[20] How Much Do Content Creators Make? Insights from 250 Creators for 2025, Blavity Inc. (Dec. 17, 2024), https://blavityinc.com/how-much-do-content-creators-make/#:~:text=Platform%20Payouts:%20Programs%20like%20TikTok,tailored%20to%20their%20audience%27s%20needs.

[21] Id.

Virtual Marriage

October 20, 2025
Family Law, Internet

Jordan Strathmann, MJLST Staffer

Throughout U.S. history, family law has continuously adapted to society’s evolving values, especially within the context of marriage. As a result, formal, ceremonial rites shifted towards doctrines that prioritize the autonomy and intent of the marrying parties.[1] For instance, one of the earliest developments in U.S. marriage was the abolition of coverture and the institution of the Married Women’s Property Acts, which helped ensure that women retained independence within their marriages, rather than occupying a subordinate role to their husbands.[2] Later, restraints on people’s choice to marry, such as those on interracial and same-sex couples, were struck down as violations of the 14th Amendment.[3] Hence, the evolution of marriage laws underscores the principle that it is the parties of a relationship, not their families or the State, who have the sole responsibility for deciding whether to marry, who to marry, and what the terms of their relationship will be.[4]

Accordingly, just as family law has adapted to societal changes, it should also evolve in response to technological advancements, especially when those changes promote the policy values of autonomy and the enhancement of freedom of choice. Digital technology, particularly over the past few decades, has become a vital component of the modern lifestyle.[5] From professional settings, such as schools and the workplace, to social interactions with friends and family, our phones, laptops, social media accounts, and internet access have become essential to participation in society.[6] The deepening of societal dependence on technology has altered the way people foster and maintain intimate relationships, specifically diminishing the importance of “direct face-to-face contact.”[7] The rise of online dating exemplifies this modern shift to digital intimacy.[8] Furthermore, changes in the social mobility of families, and equality in economic capabilities and working demands between the spouses, evidence the dwindling importance of direct personal interaction in maintaining intimacy within a relationship.[9] Instead, the “[i]nternet and mobile applications such as email, instant messaging, and video chat have become the mainstays of daily social contact with family and friends.”[10]

Hence, family law’s propensity to adapt to society, combined with its policy of encouraging equality and autonomy between partners in a relationship, and the modern predilection toward technology, suggests that the next logical step for family law is to authorize virtual marriage. In other words, more state legislatures should allow for couples to marry online rather than requiring an in-person ceremony or proceeding. Just as courts and legislatures have redefined marriage to reflect evolving notions of equality and accessibility, permitting digital ceremonies expands the institution to reflect modern realities of technology and global connectivity. The practical advantages of allowing virtual marriages, such as convenience, affordability, and flexibility for working parties, mirror family law’s broader commitment to ensuring that function of the relationship prevails or formalities.[11] Moreover, allowing couples to choose the form of their ceremony aligns with family law’s policy of minimizing state intervention and leaving to the marrying parties privacy in their personal matters.[12]

Critics may argue that the convenience and flexibility offered by online marriages undermine the institution’s integrity.[13] Some may even question the very legitimacy of online marriages in the absence of a face-to-face proceeding. However, the Supreme Court has already made clear that the substance of the marrying parties’ relationship should prevail over formalistic barriers.[14] Furthermore, eliminating the necessity of an in-person proceeding to solemnize a marriage is by no means novel; proxy marriages have been available to couples since the time of Late Roman Law.[15] While the vast majority of U.S. states have yet to permit virtual marriages, one state is ahead of the curve: Utah.

Under Utah Code § 81-2-302, a marriage license must be issued to the marrying parties by a Utah county clerk, and the officiant of the marriage must be physically present within the state of Utah at the time of solemnization of the marriage. However, the license application, license delivery, receipt, and the marriage ceremony can all be done virtually.[16] Utah still requires applicants to provide the County Clerk with pertinent information to verify their identities, including “full names, social security numbers, addresses, dates and places of birth, parents’ names, birthplaces of the parents, and the age, legal names, and identities of each applicant.”[17] Hence, although the marriage process is conducted online, safeguards are in place to prevent fraud or other illegal marriages. Utah’s current laws on marriage proceedings provide a reliable framework for other states to incorporate virtual marriages into their state laws.

As our world becomes increasingly digitized, with work meetings, school days, and even important business conferences and court proceedings being held online, it should not be seen as a drastic step for society and state legislatures to start accepting online marriage applications and ceremonies. Furthermore, marriage has always been a dynamic element of family law, adapting to societal norms and allowing the intent of the marrying parties to prevail over traditional requirements. Thus, in modern society, where individuals are more independent, mobile, and accustomed to relying on digital technology to handle matters of the utmost importance, states should consider amending their marriage laws to allow for virtual proceedings.

 

Notes

[1] See Obergefell v. Hodges, 576 U.S. 644, 650 (2015) (stating that “[t]he ancient origins of marriage confirm its centrality, but it has not stood in isolation from developments in law and society[,]” in the Court’s discussion of the Nation’s changing perspectives on marriage through history).

[2] Married Women’s Property Acts, Britannica, https://www.britannica.com/event/Married-Womens-Property-Acts-United-States-1839 (last visited Oct. 9, 2025) (explaining that Married Women’s Property Acts “expanded the rights of married women to act as independent agents” from their husbands); see also Obergefell at 659–60 (explaining that the abandonment of coverture and expansion of women’s legal rights “worked deep transformations” and strengthened the institution of marriage).

[3] See Obergefell at 665 (holding that the Court’s analysis of the 14th Amendment “compels the conclusion that same-sex couples may exercise the right to marry”); see also Loving v. West Virginia, 388 U.S. 1, 11–12 (1967) (holding that “[t]here can be no doubt that restricting the freedom to marry solely because of racial classifications violates the central meaning of the Equal Protection Clause”).

[4] See Elizabeth S. Scott, Social Norms and the Legal Regulation of Marriage, 86 Va. L.  Rev. 1901, 1905 (2000) (explaining that the “legal framework of marriage” has been deregulated through the imposition of egalitarian principles and abolition of legally mandated marital commitments through no-fault divorce laws); see also Nicola Barker, The Evolution of Marriage and Relationship Recognition in Western Jurisdictions, Progress of the World’s Women at 8–9 (Oct. 2018), https://www.unwomen.org/sites/default/files/Headquarters/Attachments/Sections/Library/Publications/2018/Discussion-paper-Evolution-of-marriage-and-relationship-recognition-in-western-jurisdictions-en.pdf (explaining that the form of marriage and family has become less important to the state).

[5] See Cherie Foo, How Does Technology Influence Our Lives, Sogolytics, https://www.sogolytics.com/blog/how-technology-influences-us/ (“Technology has become an integral part of our lives, revolutionizing the way we work, communicate, and live. From smartphones to smart homes, technology has infiltrated every corner of our existence.”) (last updated June 28, 2024).

[6] Id.

[7] See Anna M. Lomanowska & Matthieu J. Guitton, Online Intimacy and Well-Being in the Digital Age, 4 Internet Intervention 138, 139 (2016), https://pmc.ncbi.nlm.nih.gov/articles/PMC6096121/pdf/main.pdf (explaining that “physical proximity and direct face-to-face contact have become less prevalent” with society’s shift towards utilizing “[i]nternet-based communication and social networking applications” to “actualize intimacy”).

[8] According to a 2022 Pew Research survey, approximately one in three adults under the age of thirty reported using a dating site or app. See Emily A. Vogels & Colleen McClain, Key Findings About Online Dating in the U.S., Pew Rsch. Ctr. (Feb. 22, 2023), https://www.pewresearch.org/short-reads/2023/02/02/key-findings-about-online-dating-in-the-u-s/. The survey also revealed that approximately one in ten adults under the age of 30 who were married, living with a partner, or in a committed romantic relationship met their current partner through a dating site or app. Id.

[9] See generally Frank F. Furstenburg, Family Change in Global Perspective: How and Why Family Systems Change, 68 Future Healthy Fams. (Special Issue) 326 (2019) (describing how “the most important” change in the family structure was “the transition from a predominately traditional subsistence economy to a production-oriented economy transformed” which “expand[ed] a job-based economy that favors younger and more geographically mobile individuals).

[10] See Anna M. Lomanowska & Matthieu J. Guitton supra note vii at 139.

[11] Rebecca Aviel, A New Formalism for Family Law, 55 Wm. & Mary L. Rev. 2003, 2003 (2014) (explaining that, despite family law becoming more formalist in some respects, with regard to recognition of marital relationships “family law is experiencing a trend toward more flexible decision making that prioritizes functional assessment of relationships above formal legal status”); see also June Carbone & Naomi Cahn, Uncoupling, 53 Ariz. St. L.J. 1, 27 (2021) (explaining that “the new system [of legal regulation of marriage] rewards those who manage the human capital investments necessary to achieve labor market nimbleness and family relationships based on flexibility, reciprocity and trust. . .”).

[12] See Zablocki v. Redhail, 434 U.S. 374, 386 (1978) (explaining that the right to privacy within family life also extends to the choice of entering marriage).

[13] U.S. v. Windsor, 570 U.S. 744, 809 (2013) (describing how other critics of substantial changes in marriage, specifically same-sex marriage in this case, believe that those changes “will seriously undermine the institution of marriage”) (Alito J., dissenting).

[14] Obergefell at 666–67 (describing marriage as “an association that promotes a way of life, not causes; a harmony in living, not political faiths; a bilateral loyalty, not commercial or social projects”).

[15] Ernest Lorenzen, Marriage By Proxy and the Conflict of Laws, 32 Harv. L. Rev. 473, 473 (1918) (asserting that, in answering the question of whether American soldiers abroad during the ongoing World War could contract a marriage by proxy, it should be considered “[t]hat marriage by proxy was allowed in the late Roman law and in the Canon Law”).

[16] See Marriage – Frequently Asked Questions, Utah County Clerk, https://www.utahcounty.gov/dept/clerk/marriage/faq.html (last visited Sept. 27, 2025); see also Marriage Ceremonies, Utah Cnty. Clerk https://www.utahcounty.gov/dept/clerk/marriage/ceremony.html (last visited Sept. 27, 2025).

[17] Utah Code § 81-2-303.

The MLB’s Automated Ball-Strike System: The Forces Pushing Baseball Toward Full Automation

October 14, 2025
Artificial Intelligence, New Technology, Sports Law

Xavier Savard, MJLST Staffer

First shown regularly on Major League Baseball (“MLB”) broadcasts in 1997, the glowing strike zone allowed television viewers to see what umpires missed.[1] Despite technological reforms to umpiring, the most fundamental calls in professional baseball, balls and strikes, have been left entirely to human judgment since 1869.[2] In September 2025, the MLB announced the rollout of the Automated Ball-Strike System (“ABS”), allowing teams to challenge pitches that the system will then review.[3] However, this challenge-based model represents solely a transitional step towards full automation. Due to pressures surrounding legalized sports betting, fairness, and broader advances intechnological developments, a fully automated system is increasingly likely in the future, despite concerns regarding collective bargaining and player pushbacks.

Diligently tested by the MLB since 2022, ABS is a high-speed camera system that locates the ball in relation to an individualized batter’s box and translates the location data over a private network, allowing a pitcher, catcher, or batter to challenge an umpire’s call.[4] Then, within fifteen seconds, the system reviews the pitch data and analyzes whether the ball passes within the tailored strike zone within fifteen seconds.[5] If the challenge is successful, the team retains its challenge; if not, the team loses it.[6] Teams start with two challenges.[7] According to the MLB’s 2024 Spring Training testing, players favor the challenge system because it retains the human element of the game.[8]

As a fan, I admit that I agree with the players. I like human umpires. The subjective element adds a certain unpredictability and excitement to the game, giving baseball its flair. While frustrating at times, this quality makes the game feel historic and connected to humanity. Yet, enjoying the human element does not change where baseball is heading.

The MLB has an implicit duty, derived from its Constitution and the Official Baseball Rules, to strive for fairness and accuracy in baseball.[9] This fiduciary-like duty is particularly evident in the “best interests of baseball” clause, which grants the MLB Commissioner broad authority to act in the interest of maintaining baseball’s integrity.[10] While this duty has historically been fulfilled through human umpires, the MLB’s tolerance of preventable errors that technology can reduce indisputably risks the integrity of the game.

The MLB has partnered with various sports betting organizations,[11] which raises its duty to employ a fairer and more accurate umpiring system. While there is some argument that the integrity of the game includes the presence of human umpires,[12] the MLB and its fans’ substantial financial entanglement with official partnership outweighs that argument. Now, accuracy is no longer just ideal but is a business requirement to preserve the reputation of the MLB and the fans’ expectations. When the MLB profits from wagers through official partnerships on games and fans risk significant sums of money, the tolerance for officiating errors should decrease. While umpires call roughly 93% of pitches correctly, the remaining 7% can drastically affect the game.[13] For example, in Game 4 of the 2025 NLDS matchup between the Dodgers and the Phillies, the umpire called a fourth ball on a clear strike, allowing a walk.[14] That batter eventually scored, and the pitcher’s team lost.[15] While it is difficult to know what would have happened had the pitch been called a strike, the truth is, we should not have to wonder. The pitch simply should have been called a strike in the first instance. Given how efficient and accurate the ABS is, the MLB should remove errors like these from the game through a full ABS.

These concerns are only magnified by the growth of sports betting is not going away anytime soon. Since the Supreme Court’s decision in Murphy v. NCAA in 2018, the sports betting industry has grown from $400 million in revenue in 2018 to $13.71 billion in revenue by 2024.[16] As the MLB continues to earn more revenue from its partnerships, the reliance on human umpiring compromises fairness and public trust in the game.

Additionally, while traditionalists argue that baseball is a game steeped in tradition, the game has always changed to increase fairness or to strengthen its commercial value. In 1935, the MLB had its first-ever night game, powered by innovative lighting equipment to allow spectators to come to the game after work.[17] Decades later, baseball adopted instant replay in 2008, which it drastically expanded upon in 2014.[18] More recently, in 2023, the MLB implemented a pitch clock.[19] These examples show that baseball’s tradition does not actually stop it from implementing technology to promote fairness and marketability.

Yet, the challenge-based system is only a temporary solution because it only corrects a minority of errors, those that players deem valuable enough to challenge. In the past study, the players challenged about 2-3% of calls, with about half of the challenges being successful.[20] That means another 5.5% of incorrect calls remain. Put another way, the challenge-based system only corrects 20% of incorrect calls are corrected. Challenge-based ABS still simply does not ensure maximum accuracy, failing to satisfy the MLB’s fairness obligations when full ABS is available.

One major obstacle to full ABS is the Major League Baseball Umpire Association (“MLBUA”). While the 2019 and 2024 collective bargaining agreements indicate that the MLBUA has been pro-ABS to a certain extent,[21] the MLBUA is likely to oppose full-ABS. Even in a world with full ABS, umpires are still necessary to make certain calls around the bases. Due to union protections under the National Labor Relations Act (“NLRA”),[22] implementing a fully automated system could pose a significant hurdle for the MLB.

Second, a full ABS may face resistance from players because it changes some important aspects of the game for pitchers and catchers. There is some evidence that veteran pitchers get a wider strike zone that they have “earned,” and catchers spend years developing their pitch-framing abilities.[23] Full ABS would reduce the impact of these skills. Yet, all rule changes impact how players play baseball, and history shows that fairness-based rule changes often improve the game for the better. In 2021, for example, the MLB began enforcing Rules 3.01 and 6.02(c), which suspend pitchers for using sticky substances on their hands.[24] Because some players were getting an unfair advantage by the way they played the game, the MLB enforced the rule. Simply put, just because rule changes alter how players have historically done their job does not mean it is not good for the integrity of the game.

A full ABS implementation from the challenge system is entirely consistent with baseball’s long-standing technological evolutions that promote integrity and fairness. It is merely a continuation of that pattern, necessitated by legalized sports betting and immense financial interests at stake. Still, collective bargaining obligations and player pushbacks ensure the future transition will be difficult.

 

Notes

[1] How Accurate is the Baseball Strike Zone Box on TV, Baseball Scouter, https://baseballscouter.com/baseball-strike-zone-on-tv/ (last visited Sept. 29, 2025).

[2] History.Com Editors, National League of Baseball is Founded, History (last updated May 25, 2025), https://www.history.com/this-day-in-history/February-2/national-league-of-baseball-is-founded.

[3] MLB Announces ABS Challenge System Coming to the Major Leagues Beginning in the 2026 Season, MLB (Sept. 23, 2025), https://www.mlb.com/press-release/press-release-mlb-announces-abs-challenge-system-coming-to-the-major-leagues-beginning-in-the-2026-season.

[4] Id.

[5] Id.

[6] Id.

[7] Id.

[8] Theo DeRosa, MLB Releases Spring Training ABS Challenge results, MLB (Mar. 26, 2025), https://www.mlb.com/news/automated-ball-strike-system-results-mlb-spring-training-2025?msockid=2b62cc077eaa61eb013dd8dc7f816092.

[9] See Major League Baseball Constitution, MLB (2000), https://sports-entertainment.brooklaw.edu/wp-content/uploads/2021/01/Major-League-Baseball-Constitution.pdf; Official Baseball Rules, MLB (2025), https://mktg.mlbstatic.com/mlb/official-information/2025-official-baseball-rules.pdf.

[10] Richard Justice, ‘Best Interests of Baseball’ a Wide-Ranging Power, MLB (Aug. 1, 2023), https://www.mlb.com/news/richard-justice-best-interests-of-baseball-a-wide-ranging-power-of-commissioner/c-55523182#:~:text=In%201921%2C%20the%20owners%20defined,exactly%20what%20it%20sounds%20like.

[11] Sam Carp, MLB Adds FanDuel as Third Sports Betting Partner, SportsPro (Aug. 16, 2019), https://www.sportspro.com/news/mlb-fanduel-sports-betting-sponsorship/.

[12] See Larry Gerlach, History of Umpiring, Steve O’s Umpire Res., https://www.stevetheump.com/umpiring_history.htm (last visited Oct. 9, 2025).

[13] Davy Andrews, Strike Three?! Let’s Check in on Umpire Accuracy, FANGRAPHS (Feb. 1, 2024), https://blogs.fangraphs.com/strike-three-lets-check-in-on-umpire-accuracy/.

[14] Zach Bachar, Phillies’ Sanchez Says Umpire Apologized for Crucial Missed Strike 3 Call vs. Dodgers, Bleacher Rep. (Oct. 10, 2025), https://bleacherreport.com/articles/25259222-phillies-sanchez-says-umpire-apologized-crucial-missed-strike-3-call-vs-dodgers.

[15] Id.

[16] Ehtan Mordekhai, The Aftermath of Murphy v. NCAA: State and Congressional Reactions to Leaving Sports Gambling Regulation to the States, CARDOZO J. ARTS & ENT. L.J. (Oct. 17, 2023), https://cardozoaelj.com/2023/10/17/the-aftermath-of-murphy-v-ncaa-state-and-congressional-reactions-to-leaving-sports-gambling-regulation-to-the-states/.

[17] Brian Murphy, 88 Years Ago, AL/NL Baseball Finally Saw the Light, MLB (May 23, 2024), https://www.mlb.com/news/first-night-game-in-al-nl-history.

[18] Instant Replay, BASEBALL REFERENCE, https://www.baseball-reference.com/bullpen/Instant_replay (last visited Sept. 29, 2025).

[19] Pitch Timer (2023 Rule Change), MLB, https://www.mlb.com/glossary/rules/pitch-timer?msockid=2b62cc077eaa61eb013dd8dc7f816092, (last visited Oct. 9, 2025).

[20] DeRosa, supra note viii.

[21] Dylan A. Chase, MLB, MLBUA Reach Tentative Labor Agreement, MLB Trade Rumors (Dec. 21, 2019), https://www.mlbtraderumors.com/2019/12/mlb-mlbua-reach-tentative-labor-agreement.html; Manny Randhawa, MLB Reaches New CBA Agreement with Umpires Association, MLB (Dec. 23, 2024), https://www.mlb.com/news/mlb-umpires-association-reach-collective-bargaining-agreement?msockid=2b62cc077eaa61eb013dd8dc7f816092.

[22] U.S. Dep’t Lab., What Are My Employees’ Rights Under the National Labor Relations Act (NLRA)?, https://beta.dol.gov/policy-governance/protections-rights/unions-collective-bargaining/employee-rights-nlra (last visited Oct. 9, 2025).

[23] Nayima Riyaz, “Change Is Always Tough” – MLB Veteran Voices Concern Over ABS System Amid Growing Popularity, Essentially Sports (Feb 26, 2025), https://www.essentiallysports.com/mlb-baseball-news-change-is-always-tough-mlb-veteran-voices-concern-over-abs-system-amid-growing-popularity/; Veteran Bias in MLB Umpiring: Hitters, Quantum Sports (Feb. 24, 2020), https://www.quantumsportssolutions.com/blogs/baseball/veteran-bias-in-mlb-umpiring-hitters.

[24] MLB Announces New Guidance to Crack Down Against Use of Foreign Substances, Effective June 21, MLB (June 15, 2021), https://www.mlb.com/press-release/press-release-mlb-new-guidance-against-use-of-foreign-substances?msockid=2b62cc077eaa61eb013dd8dc7f816092.

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