Letter from Commissioner Robert D. Manfred, Jr. to Jeffrey M. Lenkov (Zelms Erlich Lenkov), May 13, 2025 — Policy Decision on Permanent Ineligibility Status After Death (Posthumous Reinstatement of Pete Rose and 16 Others from the Permanently Ineligible List)
From WikiLeague, the free baseball governance encyclopedia.
3-page letter from Commissioner Robert D. Manfred, Jr. to Jeffrey M. Lenkov of Zelms Erlich Lenkov (counsel to the Rose family), dated May 13, 2025, responding to Lenkov's January 8, 2025 application for posthumous removal of Pete Rose from MLB's Permanently Ineligible List. Manfred announces and applies a new policy: 'permanent ineligibility ends upon the passing of the disciplined individual.' The letter applies the policy first to Rose specifically and then by parallel reasoning to all individuals previously placed on the Permanently Ineligible List who have since died. Per the accompanying MLB press release, the policy applies retroactively to MLB's first Commissioner (Kenesaw Mountain Landis era) and reinstates 17 individuals total: Pete Rose (banned August 23, 1989, died September 30, 2024); the eight 'Black Sox' players banned by Landis in 1921 (Eddie Cicotte, Happy Felsch, Chick Gandil, Joe Jackson, Fred McMullin, Swede Risberg, Buck Weaver, Lefty Williams); and eight additional pre-1944 ineligibles (Joe Gedeon, Gene Paulette, Benny Kauff, Lee Magee, Phil Douglas, Cozy Dolan, Jimmy O'Connell, William Cox). **The doctrinal reasoning**: Rule 21 penalties serve two purposes — (1) 'protect the game from individuals who pose a risk to the integrity of the sport by prohibiting the participation of such individuals' and (2) 'create a deterrent effect that reduces the likelihood of future violations by others.' Manfred concludes that once an individual has passed away both purposes have been served: 'a person no longer with us cannot represent a threat to the integrity of the game' (purpose 1 satisfied), and 'it is hard to conceive of a penalty that has more deterrent effect than one that lasts a lifetime with no reprieve' (purpose 2 satisfied through the full-life-spent-banned outcome). **The letter explicitly does NOT make any Hall of Fame determination**: Manfred closes by emphasizing 'it is not part of my authority or responsibility to express any view concerning Mr. Rose's consideration by or possible election to the Hall of Fame. I agree with Commissioner Giamatti that responsibility for that decision lies with the Hall of Fame.' The letter also explicitly distinguishes the 1989 Rose discipline from a 'lifetime ban' — characterizing the 1989 Agreement (in archive) as 'a 1989 settlement of potential litigation with the Commissioner's Office,' with the operative penalty being placement on the 'permanently ineligible' list referenced in Rule 21 rather than a 'lifetime ban' per se. **Operational consequence**: under Hall of Fame Rule 3(E) (in archive at `governance/2026_rules_hall-of-fame-bbwaa-election-rules`) — 'Any player on Baseball's ineligible list shall not be an eligible candidate' — Rose, the Black Sox, and the other 11 are now Hall-eligible for the first time. The Era Committee (rather than the BBWAA, given that all 17 are long retired) is the operative pathway. **The letter is the most significant Rule 21 action since the 1989 Rose Agreement** and structurally reopens the doctrinal question of how Hall consideration of long-banned figures should proceed.
Background
Phase 2 wantlist hit cleared. The most operationally significant Rule 21 action since the 1989 Rose Agreement. The letter's doctrinal innovation is the move from interpreting 'permanent ineligibility' as 'lifetime' (which had been the de facto reading for 105+ years since Landis's 1921 Black Sox bans) to interpreting it as 'until death' — turning a previously-thought-permanent status into a finite-duration penalty. The implementation: Manfred articulates the policy in the letter to Lenkov but applies it across all 17 deceased Permanently Ineligible List members per the accompanying MLB press release. The non-Rose 16 individuals were not the subject of the Lenkov application; the Commissioner extends the policy by parallel reasoning, consistent with the letter's framing that the policy applies to 'all individuals previously placed on the Permanently Ineligible List who have since died.' Era Committee operational consequence: under Hall of Fame Rule 3(E), the 17 reinstated individuals are now Hall-eligible. Rose, Cicotte, Felsch, Gandil, Jackson, McMullin, Risberg, Weaver, Williams, Gedeon, Paulette, Kauff, Magee, Douglas, Dolan, O'Connell, and Cox are all long retired (the most recent active player among them was Rose, who retired in 1986), so all 17 fall under the Era Committee process rather than the BBWAA process. The Classic Baseball Era Committee or the Pre-Integration Era Committee are the structural pathways; the next eligible meeting dates are governed by Era Committee election rules. The Giamatti press-conference quote (1989 press conference following the Rose Agreement) is reproduced at length on page 2 of the letter, with Manfred explicitly endorsing Giamatti's characterization that the Hall of Fame question is the Hall's decision, not the Commissioner's. This frames the policy decision as procedural (clearing the Rule 21 obstacle) rather than substantive (Manfred takes no view on whether the now-eligible 17 should actually be elected). Procedural footnote on the 1989 settlement framing: Manfred's letter explicitly distinguishes Rose's discipline from a 'lifetime ban' — characterizing the 1989 Agreement as a settlement that placed Rose on the 'permanently ineligible' list referenced in Rule 21 rather than a 'lifetime ban' per se. This is a small but consequential framing move because it allows Manfred to apply the new policy without overturning the 1989 settlement's terms (which had committed Rose not to challenge the penalty); the penalty's substantive content was 'permanent ineligibility,' and Manfred's 2025 ruling is that 'permanent' means 'lasting until death,' a reading consistent with the 1989 Agreement's text. Companion document: the MLB press-release page accompanying the letter is at mlb.com/press-release/press-release-major-league-baseball-issues-policy-decision-on-permanent-ineligibility-status-after-death; that page lists all 17 reinstated individuals and provides the announcement framing. Not separately acquired in this pass; future-pass acquisition target.
Key provisions
- Policy holding: 'I have concluded that permanent ineligibility ends upon the passing of the disciplined individual, and Mr. Rose will be removed from the permanently ineligible list.'
- Application to Rose specifically: 'Mr. Rose is the first person banned by a Commissioner other than Kenesaw Mountain Landis to die while still on the ineligible list. As such, it is incumbent upon the Office of the Commissioner to reach a policy decision regarding this unprecedented issue in the modern era.'
- Doctrinal reasoning on Rule 21 purposes: 'penalties imposed under Rule 21 are intended to: (1) protect the game from individuals who pose a risk to the integrity of the sport by prohibiting the participation of such individuals; and (2) create a deterrent effect that reduces the likelihood of future violations by others. In my view, once an individual has passed away, the purposes of Rule 21 have been served. Obviously, a person no longer with us cannot represent a threat to the integrity of the game. Moreover, it is hard to conceive of a penalty that has more deterrent effect than one that lasts a lifetime with no reprieve.'
- Distinction from 'lifetime ban' characterization: 'The phrase 'lifetime ban' has often been used to describe the punishment agreed to by Mr. Rose and the Office of the Commissioner; however, the use of that phrase is not accurate. In fact, the 1989 agreement between Mr. Rose and the Office of the Commissioner tracks the actual language of Rule 21 and Mr. Rose was placed on the 'permanently ineligible' list referenced in Rule 21.'
- Hall of Fame disclaimer: 'In closing, I want to emphasize that it is not part of my authority or responsibility to express any view concerning Mr. Rose's consideration by or possible election to the Hall of Fame. I agree with Commissioner Giamatti that responsibility for that decision lies with the Hall of Fame.'
- Reference to Manfred's 2015 prior Rose denial: 'As you know, I denied a prior request for reinstatement from Mr. Rose in 2015. In my view, the only salient fact that has changed since that decision is that Mr. Rose has recently passed away.'
- Reference to Giamatti's 1989 press conference on Hall of Fame consideration: the letter quotes a 247-word block from Giamatti's August 1989 press conference confirming that Hall of Fame consideration was always the BBWAA's responsibility, not the Commissioner's.
Notable provisions
I write in response to your letter on behalf of the Rose family on January 8, 2025, and the request contained therein that Pete Rose be posthumously removed from the permanently ineligible list.— Letter from Manfred to Lenkov, May 13, 2025, at 1
Mr. Rose is the first person banned by a Commissioner other than Kenesaw Mountain Landis to die while still on the ineligible list. As such, it is incumbent upon the Office of the Commissioner to reach a policy decision regarding this unprecedented issue in the modern era.— Letter from Manfred to Lenkov, May 13, 2025, at 1
In my view, once an individual has passed away, the purposes of Rule 21 have been served. Obviously, a person no longer with us cannot represent a threat to the integrity of the game. Moreover, it is hard to conceive of a penalty that has more deterrent effect than one that lasts a lifetime with no reprieve. Therefore, I have concluded that permanent ineligibility ends upon the passing of the disciplined individual, and Mr. Rose will be removed from the permanently ineligible list.— Letter from Manfred to Lenkov, May 13, 2025, at 2
In closing, I want to emphasize that it is not part of my authority or responsibility to express any view concerning Mr. Rose's consideration by or possible election to the Hall of Fame. I agree with Commissioner Giamatti that responsibility for that decision lies with the Hall of Fame.— Letter from Manfred to Lenkov, May 13, 2025, at 3
Further context
Manfred Posthumous Reinstatement of Pete Rose et al. (May 13, 2025)
The 3-page Manfred-to-Lenkov letter announcing the most operationally significant Rule 21 policy decision since 1989: permanent ineligibility ends upon the death of the disciplined individual. Reinstates Pete Rose, the eight 1919 Black Sox, and eight additional pre-1944 ineligibles — 17 individuals total. Phase 2 wantlist hit cleared.
The policy, in one sentence
"Once an individual has passed away, the purposes of Rule 21 have been served... permanent ineligibility ends upon the passing of the disciplined individual."
The doctrinal reasoning
Rule 21 penalties serve two purposes:
- Protect the game from individuals who pose a risk to the integrity of the sport by prohibiting their participation.
- Deter future violations by others.
Both purposes are satisfied at death:
- A deceased person cannot threaten the integrity of the game.
- A penalty lasting an entire lifetime with no reprieve is structurally the maximum deterrent.
The 17 reinstated
- Pete Rose (banned Aug 23, 1989; died Sep 30, 2024).
- The 1919 Black Sox (banned 1921 by Landis): Eddie Cicotte, Happy Felsch, Chick Gandil, Joe Jackson, Fred McMullin, Swede Risberg, Buck Weaver, Lefty Williams.
- Additional pre-1944 ineligibles: Joe Gedeon, Gene Paulette, Benny Kauff, Lee Magee, Phil Douglas, Cozy Dolan, Jimmy O'Connell, William Cox.
What the letter explicitly does NOT do
Manfred does not make any Hall of Fame determination. He explicitly quotes Giamatti's 1989 framing: "responsibility for that decision lies with the Hall of Fame." Under Hall Rule 3(E) (in archive), the 17 are now Hall-eligible; the Era Committee process (rather than the BBWAA process, given all 17 are long retired) is the structural pathway forward.
Doctrinal subtlety: not a "lifetime ban"
Manfred's letter explicitly disclaims the "lifetime ban" characterization that has been universal in the popular literature on the Rose case. The 1989 Agreement (in archive at 1989-08-23_agreement_rose-giamatti-permanent-ineligibility) places Rose on the "permanently ineligible" list referenced in Rule 21 — and Manfred's 2025 reading is that "permanent" means "until death," not "lasting beyond death." This framing preserves the 1989 settlement's procedural commitments while reopening eligibility.
Verification status
needs_review — primary-publisher PDF from MLB's CDN on file. Sportico (Penske Media) is the cleanest independent contemporaneous reproduction with verbatim quoted language; Wayback snapshot capture pending. Structural single-publisher problem applies (same as other MLB discipline documents in the archive).
Related documents in the archive
1989-08-23_agreement_rose-giamatti-permanent-ineligibility.md— the 1989 Agreement this letter amends.../governance/2026_rules_hall-of-fame-bbwaa-election-rules.md— Hall of Fame Rule 3(E), the operative Hall-eligibility provision affected by this letter.../reports-and-investigations/1989-05-09_report_dowd-rose-investigation.md— the underlying Dowd Report on Rose.
References
- Primary source: img.mlbstatic.com — Major League Baseball, Office of the Commissioner, retrieved 2026-05-19.
- Confirmation source: img.mlbstatic.com — Major League Baseball (img.mlbstatic.com CDN). Primary publisher's CDN-hosted PDF of the signed Manfred-to-Lenkov letter. 3 pages. PDF version 1.6. Letter opens 'May 13, 2025' / 'Dear Mr. Lenkov,' and closes with Manfred's signature on page 3 over his typed signature block. Downloaded directly via curl on 2026-05-19; SHA256 recorded below.
- Confirmation source: sportico.com — Sportico. Independent contemporaneous coverage reproducing direct quoted language from the Manfred letter. Sportico is independently owned (Penske Media Corporation, no MLB ownership). The Sportico article quotes the letter language verbatim, confirming the content of the MLB-hosted PDF.
- File fingerprint: SHA256 b13fb5055f5587267706584929cc112ec38f7844c89945e5e6c3c62f45918b47.
Evidence trail
Per archive editorial standards §1.3 and §1.4, verified documents require two independent confirmation sources and an archive.org snapshot. This panel is the integrity record the archive holds for this document.
File integrity
- SHA256
b13fb5055f5587267706584929cc112ec38f7844c89945e5e6c3c62f45918b47- Filename
2025-05-13_letter_manfred-rose-posthumous-reinstatement.pdf- Format
- PDF · 3 pp · 141 KB
- Retrieved
- 2026-05-19 by
claude/cowork-9167cb28 - Primary URL
- https://img.mlbstatic.com/mlb-images/image/upload/mlb/nygssehtiivswdtymqso.pdf
Confirmation sources (2)
| Publisher | Retrieved | URL | Notes |
|---|---|---|---|
| Major League Baseball (img.mlbstatic.com CDN) | 2026-05-19 | https://img.mlbstatic.com/mlb-images/image/upload/mlb/nygssehtiivswdtymqso.pdf | Primary publisher's CDN-hosted PDF of the signed Manfred-to-Lenkov letter. 3 pages. PDF version 1.6. Letter opens 'May 13, 2025' / 'Dear Mr. Lenkov,' and closes with Manfred's signature on page 3 over his typed signature block. Downloaded directly via curl on 2026-05-19; SHA256 recorded below. |
| Sportico | 2026-05-19 | https://www.sportico.com/leagues/baseball/2025/rose-black-sox-reinstated-mlb-hall-of-fame-eligible-1234852373/ | Independent contemporaneous coverage reproducing direct quoted language from the Manfred letter. Sportico is independently owned (Penske Media Corporation, no MLB ownership). The Sportico article quotes the letter language verbatim, confirming the content of the MLB-hosted PDF. |
Most recent status change
needs_review on 2026-05-19 by claude/cowork-9167cb28.
**Phase 2 wantlist hit cleared.** 3-page Manfred-to-Lenkov letter PDF acquired direct from MLB CDN. Same structural two-source problem as other MLB-issued discipline documents; status held at `needs_review` consistent with other Commissioner documents. Sportico (Penske Media) is independent and reproduces verbatim language. Wayback snapshot capture pending.