William S. Stevens
Encyclopedia
William Stanley Stevens was an American
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...

 lawyer
Lawyer
A lawyer, according to Black's Law Dictionary, is "a person learned in the law; as an attorney, counsel or solicitor; a person who is practicing law." Law is the system of rules of conduct established by the sovereign government of a society to correct wrongs, maintain the stability of political...

 best known for his June 1975 law review article The Common Law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...

 Origins of the Infield Fly Rule
Infield Fly Rule
The infield fly rule is a baseball rule that is intended to prevent infielders from intentionally dropping pop-ups in order to turn double plays . Without this rule, a defense could easily turn a pop-up into a double play when there are runners at first and second base...

, which treated the development of one of baseball's most-misunderstood rules as if it were a legal matter.

Early life and Education

Stevens was born in Orange, New Jersey
Orange, New Jersey
The City of Orange is a city and township in Essex County, New Jersey, United States. As of the 2010 United States Census, the township population was 30,134...

 and grew up in Millburn Township. He attended Yale University
Yale University
Yale University is a private, Ivy League university located in New Haven, Connecticut, United States. Founded in 1701 in the Colony of Connecticut, the university is the third-oldest institution of higher education in the United States...

, where he earned a bachelor's degree in 1970. He served for two years as an officer in the United States Navy
United States Navy
The United States Navy is the naval warfare service branch of the United States Armed Forces and one of the seven uniformed services of the United States. The U.S. Navy is the largest in the world; its battle fleet tonnage is greater than that of the next 13 largest navies combined. The U.S...

 and was awarded a law degree in 1975 from the University of Pennsylvania Law School
University of Pennsylvania Law School
The University of Pennsylvania Law School, located in Philadelphia, Pennsylvania, is the law school of the University of Pennsylvania. A member of the Ivy League, it is among the oldest and most selective law schools in the nation. It is currently ranked 7th overall by U.S. News & World Report,...

.

Infield Fly Rule

The Infield Fly Rule (now covered by Major League Baseball rules 6.05e and 2.00), was adopted in the 1890s to prevent situations in which fielders could take advantage of base runners by intentionally allowing a ball to drop with runners on first and second or bases loaded and less than two outs in order to turn a double play
Double play
In baseball, a double play for a team or a fielder is the act of making two outs during the same continuous playing action. In baseball slang, making a double play is referred to as "turning two"....

 or triple play
Triple Play
A triple play is a baseball play in which three outs are made as a result of continuous action without any intervening errors between outs.Triple play may also refer to:...

 on the base runners. In such circumstances, the Infield Fly Rule is invoked at the umpire's discretion if a fair fly ball can be caught by an infielder "with ordinary effort", and the batter is automatically out. The rule was first implemented in the short-lived Players' League in 1890 and adopted by the National League and American Association of Base Ball Clubs in 1894, applying only if a fly ball could be handled by an infielder with a runner on first base occupied and only one out, with additional changes made in subsequent years.

Stevens was fascinated by the incremental development of the rule and the way in which the rule's formal, step-by-step development mirrored the process by which the common law was created. The semi-parodic paper was thoroughly footnoted to show how the rule was needed in an era in which unseemly behavior was taking place that would not have been accepted in the sport's earlier gentlemanly age.

In addition to its sometimes-humorous commentaries on baseball, the article is a parody of the style in which law review articles are generally written, such as their sometimes overly-formal wording and their often-excessive use of footnoting. The very first word of the article, "The", is supported by an unnecessary citation to the Oxford English Dictionary. The second time the word "the" appears, another footnote appears (footnote 4), which merely refers back to the first footnote. A more complex example of parody appears when the text refers to a late-19th century baseball player who was said to have "the speed of an ice wagon," followed by a footnote stating: "Raised by this statement is the issue of the speed of an ice wagon in both relative and absolute terms. Such inquiry is beyond the scope of this Aside."

Soon after it was published, a slew of imitators were written, including Further Aside: A Comment on ‘The Common Law Origins of the Infield Fly Rule’,
The Infield Fly Rule and the Internal Revenue Code: An Even Further Aside, Strict Constructionism and the Strike Zone, in re Brett
Pine Tar Incident
The Pine Tar Incident was a controversial incident during an American League game played between the Kansas City Royals and New York Yankees on July 24, 1983 at Yankee Stadium in New York City. With his team trailing 4–3 in the top half of the ninth inning, George Brett of the Royals hit a 2-run...

: The Sticky Problem of Statutory Construction
, and The Contribution of the Infield Fly Rule to Western Civilization (and Vice Versa). His paper has been referenced in legal articles covering bankruptcy
Bankruptcy
Bankruptcy is a legal status of an insolvent person or an organisation, that is, one that cannot repay the debts owed to creditors. In most jurisdictions bankruptcy is imposed by a court order, often initiated by the debtor....

, constitutional law
Constitutional law
Constitutional law is the body of law which defines the relationship of different entities within a state, namely, the executive, the legislature and the judiciary....

 and ethics.

Career

He worked for a number of law firms in the Philadelphia area and became assistant director of the American Law Institute
American Law Institute
The American Law Institute was established in 1923 to promote the clarification and simplification of American common law and its adaptation to changing social needs. The ALI drafts, approves, and publishes Restatements of the Law, Principles of the Law, model codes, and other proposals for law...

 and of the American Bar Association
American Bar Association
The American Bar Association , founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation...

's Continuing Legal Education
Continuing Legal Education
Continuing legal education is professional education of lawyers that takes place after their initial admission to the bar. In many states in the United States, CLE participation is required of attorneys to maintain their license to practice law...

 program. After retiring in September 2008, he accepted a one-year assignment as the acting director of the continuing education program of the Alaska Bar Association.

He wrote numerous articles during his legal career, including work for The Philadelphia Lawyer, but none achieved the renown of his Infield Fly Rule note.

A resident of Narberth, Pennsylvania
Narberth, Pennsylvania
Narberth is a borough in Montgomery County, Pennsylvania, United States. The population was 4,282 at the 2010 census.-History:Narberth is located on a parcel of land originally deeded to Edward Rees , who arrived from Wales in 1682. A portion of this original tract became the farm of Edward R...

, Stevens died at age 60 on December 8, 2008 of a heart attack
Myocardial infarction
Myocardial infarction or acute myocardial infarction , commonly known as a heart attack, results from the interruption of blood supply to a part of the heart, causing heart cells to die...

 while working in Anchorage, Alaska
Anchorage, Alaska
Anchorage is a unified home rule municipality in the southcentral part of the U.S. state of Alaska. It is the northernmost major city in the United States...

.

Further reading

Spencer Weber, Neil B. Cohen,& Paul Finkelman, Baseball and the American Legal Mind, Garland Publishing, Inc. (1995); ISBN 0815320574, ISBN 9780815320579; . Includes The Common Law Origins of the Infield Fly Rule and the other articles cited above.

External links

  • Legal Scholarship on the Infield Fly Rule, Klutznick Law Library, Creighton University School of Law
    Creighton University School of Law
    Creighton University School of Law is a part of Creighton University. Founded in 1904, Creighton Law is one of 14 Jesuit Catholic law schools in the U.S. One out of every 10 American law students is enrolled in a Jesuit law school. Situated primarily in urban centers, these schools were...

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