Real Life Superpowers: Service Time Manipulation in the MLB and Efforts to Contain it

By: Mason Cole*                                                                                   Posted: 11/4/2024

Stopping Time: Rowdy Tellez Loses $200,00 in One Day 

On September 24, Pittsburgh Pirates’ first basemen Rowdy Tellez was only four plate appearances away from receiving a $200,000 performance bonus.[1]  On the day of the game that he may have earned that bonus, he was released.[2]  The Pirates General Manager (GM) provided various reasons for why Tellez was released, ensuring that the bonus had “zero factor” in the decision.[3]  Tellez’s performance throughout the season had been extremely subpar.[4]  The GM also pointed out that the Pirates wanted to allow younger players in the minor leagues to get some major league playing time to prepare for the 2025 season.[5]  This was a good idea, as the Pirates had no chance of making the post-season.[6]  However, the Pirates were not in playoff contention far before when they decided to release Tellez.[7]  Instead, the Rowdy Tellez situation showcased the difficulty in actually proving underhanded tactics by MLB teams regarding player service time, as there always exists a valid reason for taking the actions they do.[8]

Service Time: An MLB Player’s Age

Service time refers to the amount of time an MLB player has played in the major leagues; accumulating every day a player spends on the 26-man major league roster or the major league injured list.[9]  This time is extremely important for MLB players, as the amount of service time correlates with important milestones for players.[10]  It is also extremely significant for rookies, as a player does not lose their rookie status until they have exceeding one of two thresholds in a prior season: (1) “130 at-bats or fifty innings pitched in the Major Leagues”; or (2) “forty five total days on an active Major League roster during the Championship Season.”[11]  Importantly, if a team delays promoting a player to the major league roster for two to three weeks, they stand to gain a whole extra season of control over the player, as that first season will not constitute a full year of service time for the player.[12]

Service time manipulation is illegal under the Collective Bargaining Agreement (CBA) between the MLB Players Association and the MLB.[13]  Even with this, teams continue to delay calling up prospects in order to get the free year of control.[14]  Recently, MLB and the MLBPA have implemented new policies to attempt to discourage service time manipulation.[15]  First, the CBA now allows players who finish first or second in Rookie of the Year voting to earn a year of service time.[16]  Second, the CBA implemented a Prospect Promotion Incentive Program (PPI).[17]  The PPI designates players before the season starts who, if they gain one year of service time as a rookie, can earn their team a draft pick if the player factors into a major award.[18]  

Is Time Flowing Naturally? Solutions to Prevent Service Time Manipulation

Restrictions on service time manipulation do very little to actually prevent teams from getting in trouble.[19]  This is because general managers can easily point to a slew of reasons as to why they prevent a player from earning a year of service time.[20]  These reasons give teams enough plausible deniability that there is not much that players can do to counter it.[21]  Sometimes, these reasons hardly hide the true intentions of teams to manipulate a player’s service time.[22]  However, sometimes teams have completely legitimate reasons for sending or keeping a player in the minor leagues.[23]  Punishing teams for sending players down when they have legitimate reasons for doing so would be counterintuitive.[24]  It is similarly difficult to punish a team for sending down or keeping down a player when they can articulate any legitimate reason for doing so.[25]  There is also no downside to this; why would a team sacrifice the chance to pay a player less and to control the player for an extra season?[26]  The answer is that there is none, because the entire incentive in the past was for teams to manipulate service time for their players.[27]

The new clause in the CBA also will disincentivize teams from manipulating service time as players will still just earn a year of service time if they place in rookie of the year voting.[28]  However, only four rookies will be eligible for this benefit, and it is extremely unpredictable as to whether a rookie player will win rookie of the year.[29]  For example, 350 players lost their rookie status in the 2023 season and only 4 players will get either first or second in rookie of the year voting.[30]  Because of this, there is still a great incentive for teams to manipulate a prospect’s service time to get that extra year of control.[31]

If punishing teams is not possible, then the only other option is to incentivize them not to manipulate service time.[32]  The PPI program is one of the massive shifts in incentives.[33]  The draft picks provided by the PPI cannot be scoffed at.[34]  This is further enhanced by the fact that players may earn a year of service if they get rookie of the year.[35]  This incentive for teams does seem to be making a difference.[36]  In 2022, five out of nine top prospects who were on the major league roster on May 31 also made the opening day roster.[37]  This is in stark contrast to 2019, where only 4 out of 12 made the opening day roster.[38]  However, these incentives do not nearly cover the entirety of MLB prospects.[39]  In order for a player to be PPI eligible, they must appear in two of three preseason top 100 prospects rankings.[40]  Further, the chance of earning the PPI draft is even more narrow than the CBA rule granting a year of service as a player must win the rookie of the year award for PPI, whereas the CBA rule requires only that a player place first or second in rookie of the year voting.[41]  This means the vast majority of players, who have no chance to win rookie of the year, will still be at risk of having their service time manipulated.[42]  A solution to this problem would be to continue implementing incentives for teams to ensure their players earn the service times they deserve.[43]  But it would be hard to formulate incentives for teams to play their lower ranked prospects, as there are no reasonable awards to tie to their performance.[44]

Ultimately, the problem with time service manipulation is still rampant within the MLB.[45]  The new rules do seem to be alleviate the problem regarding top prospects, but those who are not top prospects are still vulnerable to the whims of teams.[46]  This is a subject with many nuances but given the progress that has been made of now, it is hopeful that the MLBPA will continue to work to prevent this practice.[47]

* Staff Writer, Jeffrey S. Moorad Sports Law Journal, J.D. Candidate, May 2026, Villanova University Charles Widger School of Law

[1] See ESPN News Services & Associated Press, Pirates Cut 1B Rowdy Tellez Four Plate Appearances Shy of Bonus, ESPN (Sept. 24, 2024, 3:59 PM), https://www.espn.com/mlb/story/_/id/41422039/eliminated-pirates-dfa-veterans-rowdy-tellez-michael-taylor (explaining story behind Tellez’s release and quoting Pirates’ General Manager)

[2] See id. (noting Tellez’s release just four plate appearances shy of his bonus).  The Pirates also released outfielder Michael A. Taylor on the same day.  See id. (noting two releases were followed up with promotion of two Triple-A level players).

[3] See id. (quoting Pirates general manager Ben Cherrington who said release was “difficult part of the business” but that “[the Pirates] feel like we gave Rowdy lots of opportunity here this year”).

[4] See Rowdy Tellez, MLB, https://www.mlb.com/player/rowdy-tellez-642133 (last visited Oct. 4, 2024) (providing basic player career and regular season statistics).  In the fifteen games before his release, Tellez’s batting average was .116; this is a relatively low average for the MLB.  See id. (providing player statistics for Tellez’s previous seven games, fifteen games, and thirty games).  Tellez had a .220 batting average over the thirty games before his release, while also having  -0.4 wins above replacement (WAR), a below average OPS, and negative Defensive Runs Saved (DRS) during the season.  See Rowdy Tellez, Baseball Ref., https://www.baseball-reference.com/players/t/tellero01.shtml (last visited Oct. 4, 2024) (listing basic and advanced player statistics for Rowdy Tellez).

[5] See ESPN News Services & Associated Press, supra note 1 (quoting Pirates GM, who said “there are 28 [roster] spots, and 14 are going to go to position players. We feel like we have to get the 14 guys on the team, wherever we can, who have the best chance to contribute past this year”).

[6] See Standings, MLB, https://www.mlb.com/pirates/standings/ (last visited Oct. 3, 2024) (illustrating that Pirates’ regular season record was 76-86, with Pirates being 13 games back from wildcard spot).

[7] See Schedule, MLB, https://www.mlb.com/pirates/schedule/2024-09 (last visited Oct. 4, 2024) (listing team schedules and scores of each game).  The Pirates ultimately went 3-3 in those final six games.  See id. (listing outcomes of games that took place from September 24, 2024, to September 29, 2024).  

[8] See generally Mike Axia, Twins GM Admits Service Time Played a Role Into Why Byron Buxton was Kept in the Minors, CBS Sports (Sep. 2, 2018, 11:01 AM), https://www.cbssports.com/mlb/news/twins-gm-admits-service-time-played-a-role-into-why-byron-buxton-was-kept-in-the-minors/ (example explaining how team can provide just enough plausible deniability to hide it’s true, underhanded, intentions).

[9] See Service Time, MLB, https://www.mlb.com/glossary/transactions/service-time (last visited Oct. 4, 2024) (defining service time and conditions for gaining service time).  “One year” of Major League service time comes upon accruing 172 days of service time in a season.  See id. (“A player is deemed to have reached ‘one year’ of Major League service upon accruing 172 days in a given year.”). 

[10] See id. (explaining that service time is “important to players and clubs alike”).  For example, when a player reaches six years of service time, they become eligible for free agency, where the player’s team no longer holds complete control over the player.  See id. (explaining that player becomes eligible for free agency at end of season after player achieved six years of service). 

[11] See Rookie Eligibility, MLB, https://www.mlb.com/glossary/rules/rookie-eligibility (last visited Oct. 4, 2024) (explaining requirements for player to be classified as rookie).

[12] See Service Time, supra note 9 (explaining that regular seasons consist of 187 days, and players needs at least 172 days of service time to have reached “one year” of service).  There are massive benefits to waiting to call up a minor league prospect, as it will allow teams to essentially get a free extra year of control over the player and extend the amount of time they are allowed to pay a league-minimum salary.  See id. (showing discrepancy between time required to earn year of service verses length of season).

[13] See Michael Baumann, Is the New CBA Really Combatting Service Time Manipulation? Sort of, Fan Graphs (Mar. 28, 2023), https://blogs.fangraphs.com/is-the-new-cba-really-combating-service-time-manipulation-sort-of/ (explaining that service time manipulation is “black-letter illegal under the CBA”); see also Patrick Kessock, Out of Service: Does Service Time Manipulation Violate Major League Baseball’s Collective Bargaining Agreement?, 57 B.C. L. Rev. 1367, 1391–92 (Sept. 28, 2016) (explaining potential for MLB players to allege breach of CBA through time service manipulation).

[14] See, e.g., Mike Axisa, Cubs Win Kris Bryant Service Time Case: Bryant Will Become Free Agent After 2021, Per Report, CBS Sports (Jan. 30, 2020, 12:39 PM), https://www.cbssports.com/mlb/news/cubs-win-kris-bryant-service-time-case-bryant-will-become-free-agent-after-2021-per-report/ (providing background of Kris Bryant’s arbitration case).  Kris Bryant, considered one of the best prospects in baseball, was left on the Chicago Cubs’ minor league roster for the first eight games in the 2015 regular season.  See id. (listing Bryant’s impressive spring training stats and noting how Cubs left Bryant off opening day roster).  This allowed the Cubs to hold control over Bryant for an extra season.  See id. (“Had Bryant been on the Opening Day roster, he would have qualified for free agency following the 2020 season. Instead, the Cubs kept him in Triple-A just long enough to push his free agency back to the 2021-22 offseason.”).  Bryant and the MLB Players Association (MLBPA) filed a grievance, but ultimately an arbitration board sided with the Cubs.  See id. (discussing arbiter’s ruling that Bryant would become free agent following 2021 season, rather than 2020 season which Bryant requested).  The Cubs General Manager cited defensive concerns as reason why Bryant remained in the minor leagues.  See id. (quoting president of baseball operations Theo Epstein who wanted Bryant to “get in a good rhythm defensively before he makes his major league debut”); see also Kessock, supra note 13, at 1368 (describing Bryant’s situation and success in major leagues).  Bryant ultimately ended the season leading the league in on-base percentage, slugging, home runs, and became the rookie of the year.  See Kessock, supra note 13, at 1368 (discussing Bryant’s history as high caliber player); see also Baumann, supra note 13 (listing top 50 prospects and when they were called up to major league throughout years).  In 2019, only four of the top fifty prospects who made it to the major leagues by May 31 made the opening day roster, with eight prospects having their promotion delayed until after May 31, thus preventing them from earning a year of service time.  See Baumann, supra note 13 (providing graph of 2019 top prospects and whether they made opening day roster or May 31 roster).

[15]  See Baumann, supra note 13 (noting new rules that have incentivized teams to promote prospects early)

[16] See MLB & MLB Players’ Ass’n, Collective Bargaining Agreement 357–58 (Mar. 10, 2022) [hereinafter MLB & MLBPA CBA], https://www.mlbplayers.com/_files/ugd/4d23dc_d6dfc2344d2042de973e37de62484da5.pdf (confirmation letter agreeing to permit players who finish first or second in rookie of year voting to earn year of service time, regardless of time played that season).

[17] See Joe Trezza, Here Are the Players Who Could Earn Teams Extra Draft Picks This Year, MLB (Feb. 6, 2024), https://www.mlb.com/news/prospect-performance-incentive-ppi-eligible-players (explaining that latest CBA added PPI, which has already benefited teams).

[18]  See id. (explaining that rookie either needs to win “Rookie of the Year” or place top three in MVP or Cy Young voting to earn draft pick for his team).  The Seattle Mariners were awarded the 29th overall draft pick as a result of rookie Julio Rodriguez winning rookie of the year in 2022.  See id. (providing examples of benefits teams have already acquired as result of new rules).

[19] See Baumann, supra note 13 (“Service time manipulation is black-letter illegal under the CBA, but in practical terms it’s been practically impossible to prove – so much so that executives can talk openly about doing it without fear of repercussion.”).

[20] See Mike Axia, Twins GM Admits Service Time Played a Role Into Why Byron Buxton Was Kept in the Minors, CBS Sports (Sept. 2, 2018, 11:01 AM), https://www.cbssports.com/mlb/news/twins-gm-admits-service-time-played-a-role-into-why-byron-buxton-was-kept-in-the-minors/ (discussing interview with Twins’ General Manager).  The Twins General Manager provided three reasons for why Buxton was not being called up: a lingering injury, his Triple-A performance being underwhelming, and not enough playing time available in the majors.  See id. (providing list of GM’s reasons for not calling Buxton up and providing Buxton’s season stats).

[21] See Jason Wojciechowski, The Kris Bryant Situation, as Explained by a Labor Lawyer, VICE
 (Apr. 2, 2015, 2:00 PM), https://www.vice.com/en/article/the-kris-bryant-situation-as-explained-by-a-labor-lawyer/ (noting that teams likely get deference in arbitration regarding their reasons for delayed promotions). 

[22] See Axia, supra note 20 (noting that General Manager’s reasons for keeping Byron Buxton down were “just plausible enough to hide the team’s true intention: service time manipulation”).  According to Axia, if Buxton had a lingering injury, the team could have sent him to get tested, and they could very easily find playing time for him if the team wanted to.  See id. (critiquing reasons provided by Twins’ GM).

[23] See, e.g. Mike Axia, Jackson Holliday Demoted: Orioles Top Prospect Sent to Triple-A Norfolk After Struggling in First 10 MLB Games, CBS Sports (Apr. 26, 2024, 4:59 PM), https://www.cbssports.com/mlb/news/jackson-holliday-demoted-orioles-top-prospect-sent-to-triple-a-norfolk-after-struggling-in-first-10-mlb-games/ (describing Holliday’s struggles in major leagues).  Jackson Holliday was called up to the major leagues on April 10, allowing him to earn a year of service time if he played the rest of the season, but was ultimately sent back down to the minors on April 26.  See id. (explaining that “the demotion does have service time implications for Holliday).  In his first ten games, Holliday was two for thirty-four with two walks and eighteen strikeouts.  See id. (claiming that Holliday’s demotion “is not egregious” because of his struggles).

[24] See generally id. (noting that Jackson Holliday was two for thirty-four in his first ten major league games).

[25] See Axia, supra note 20 (noting General Manager’s reasons for keeping Byron Buxton down in minor leagues are “just plausible enough”).  For further discussion of the reasons given for keeping Byron Buxton in the minor leagues, see supra note 20 and accompanying text.

[26] See Kessock, supra note 13, at 1382–84 (explaining that avoiding salary arbitration is significant incentive to manipulate service time, with avoiding free agency for as long as possible is team’s “greatest incentive”).

[27] See Baumann, supra note 13 (“Service time manipulation is black-letter illegal under the CBA, but in practical terms it’s been practically impossible to prove — so much so that executives can talk openly about doing it without fear of repercussion.”).

[28] See generally MLB & MLBPA CBA, supra note 16, at 357–58 (agreement allowing players to earn year of service time if they place first or second in rookie of year voting “irrespective of how many days of credited Major League service he otherwise would have accrued for that season”).

[29] See Here Are the Rookie of the Year Vote Totals, MLB (Nov. 14, 2022), https://www.mlb.com/news/2022-mlb-rookie-of-the-year-voting-totals (listing voting totals for rookie of year candidates for both American League and National League).

[30] See 2023 Major League Baseball Rookie Players, Baseball Reference, https://www.baseball-reference.com/leagues/majors/2023-rookies.shtml (last visited Oct. 20, 2024) (listing all players who were classified as rookies in 2023).

[31] For further discussion of the various benefits of manipulating service time for rookies, see supra notes 9–11 and accompanying text.

[32] See Baumann, supra note 13 (“Absent enforcement of the actual rules, the new CBA aimed to move the incentives, which is what you do in a capitalist society; rather than using regulatory power to confront corporate malfeasance directly, you offer businesses incentives to play by the rules.”).

[33] For further discussion of the PPI program, see supra notes 17–18 and accompanying text. 

[34] See Matt Eddy, Prospect Promotion Incentive: Explaining PPI Rules, Quirks & More, Baseball Am. (Sep. 6, 2024), https://www.baseballamerica.com/stories/prospect-promotion-incentive-explaining-ppi-rules-quirks-more/#:~:text=The%20Prospect%20Promotion%20Incentive%20rewards,MLB%20and%20the%20players'%20union  (noting that draft picks gained from PPI have been between twenty-ninth and thirty-second overall).

[35]For further discussion of how players can earn a year of service time from winning rookie of the year, see supra note 16 and accompanying text.

[36] See Baumann, supra note 13 (noting growing trend in teams placing their top prospects on opening day roster).

[37] See id. (charting top fifty prospects and when they were added to major league rosters).  One prospect who was called up after the window to earn a year of service time was #1 prospect Adley Rutschman.  See id. (indicating that Rutschman was on neither opening day roster nor May 31 roster in 2021).  Rutschman ultimately earned a year of service time because he came in second place in rookie of the year voting in 2022.  See Here Are the Rookie of the Year Vote Totals, MLB (Nov. 14, 2022), https://www.mlb.com/news/2022-mlb-rookie-of-the-year-voting-totals (providing Rutschman’s 60 voting  “points” to first place Julio Rodriguez’s 148).

[38] See Baumann, supra note 13 (noting trend where more teams place their top prospects on opening day roster).

[39] See generally 2023 Major League Baseball Rookie Players, supra note 30 (listing all 350 players who lost their rookie eligibility)

[40] See Eddy, supra note 34 (providing 3 applicable top 100 prospect rankings: (1) Baseball America; (2) ESPN; and (3) MLB.com)

[41] Compare Eddy, supra note 34 (“Team acquires a draft pick after the first round if a PPI-eligible player: (1) wins the AL or NL Rookie of the Year; (2) places top three for the AL or NL MVP before qualifying for arbitration; or (3) places top three for the AL or NL Cy Young Award before qualifying for arbitration.”), with MLB & MLBPA CBA, supra note 16, at 357–58 (explaining that MLB player earns year of service if they place first or second in rookie of year voting).  Rookies who are classified as “foreign professionals” by MLB and players who sign contracts prior to his MLB debut are also ineligible for PPI.  See Eddy, supra note 34 (“A foreign professional is a player who is at least 25 years old and has played as a professional in a foreign league—typically in Japan, Korea or Cuba—for a minimum of six seasons before signing with an MLB organization.”).

[42] Compare 2023 Major League Baseball Rookie Players, supra note 30 (listing all 350 players who lost their rookie eligibility), with Eddy, supra note 34 (explaining how player must be top-100 prospect, and win rookie of year to earn PPI bonus).

[43] See generally Baumann, supra note 13 (arguing that incentives have made teams more likely to promote their top prospects early).

[44]  See MLB Awards, MLB, https://www.mlb.com/awards (last visited Oct. 20, 2024) (listing all of MLB’s awards, such as: MVP, Cy Young, Rookie of Year, Gold Glove, Silver Slugger, and Comeback Player of Year).

[45] See Baumann, supra note 13 (arguing that service time manipulation is still problem, and that there “might not be a carrot you could dangle in front of the premier tightwad franchises in baseball that would get them to promote their top prospects early”).

[46] See id. (noting how service time manipulation of top prospects is not as rampant as it was before new rules).

[47] For further discussion of the complicated nature of proving service time manipulation, see supra notes 19–27 and accompanying text.