In the late 19th and early 20th centuries playing baseball on Sundays was a criminal offense in many states, where police often aggressively intervened to prevent or stop baseball games from being played on the Sabbath. In 1894, “the police of the city of Brooklyn took it upon themselves to chase, club and lock up all boys and men found playing ball on Sunday,” People ex rel. Poole v. Hesterberg, 43 Misc. 510, 89 N.Y.S. 498, 499 (N.Y. Sup. Ct. Kings County 1904); on two consecutive Sundays in July 1910, two professional baseball teams attempting to play in Chemung County, New York were “prevented from doing so by [sheriff’s] deputies,” Southern Tier Baseball Ass’n of Elmira v. Day, 69 Misc. 53, 125 N.Y.S. 733, 733 (N.Y. County Ct. Chemung County 1910); and on Sunday, May 17, 1925, two professional baseball teams endeavored to play a game before 5,000 fans in Norfolk County, Virginia, whereupon “[a]t the end of the first inning the [police] officers stopped the game and arrested the players and the umpires, who were tried and convicted and sentenced,” Crooks v. Commonwealth, 147 Va. 593, 136 S.E. 565, 566 (1927).
Wilkes, Donald E. Jr., "Habeas Corpus and Baseball" (2006). Scholarly Works. Paper 225.