On Lawsuits for Licenses: The Fight for Women’s Wrestling in New York, part 1

This is the first post of a multi-part essay on the legislative history of the New York State Athletic Commission’s ban on women’s professional wrestling and its overturn in 1972. I didn’t think my research would ever have any relevance to anything  or anyone other than a die-hard feminist wrestling history nerd. I was wrong.

This past weekend a woman wrestler was prohibited from participating in an intergender wrestling match by a man Commission deputy.

He was wrong.

Sources not linked in text are numbered and can be found at the bottom.

A hundred years ago, on February 29, 1916, “Battling” Hildredth Whitehouse, a woman bantamweight boxer, stepped between the ropes at Grupp’s Gymnasium on 116th Street in New York City. Whitehouse claimed to be “the First Lady to have received a permit to fight in  licensed club” (1).

New-York Tribune, March 1, 1916, via Library of Congress

Her opponent, Jack Atkinson, was a man. The match was stopped in the second round when a police detective rushed the ring and put an end to the proceedings. “In the name of the law. This brutality must cease!” the New-York Tribune quoted a Detective Lynch as saying. “The Boxing Commission shouldn’t have done it.”


hildredth 2
New-York Tribune, March 1, 1916, via Library of Congress

On August 19, 2016, another intergender bout — a wrestling match in Brooklyn held a century later — was also interrupted. Not by an officer of the law stopping a match that violated his own beliefs, regardless of approvals, permits, or legality. Instead, the match between Jessie Brooks and Marc Hauss was stopped by a New York State Athletic Commission deputy who was ignorant of his own agency’s rules and regulations; he believed such a match was illegal under current Commission guidelines.

He was wrong. So very, very wrong. And the match went on.

Intergender matches are barred under the rules of boxing. Not wrestling.

The New York State Athletic Commission has, historically, discriminated against women wrestlers (and boxers) — it has also, historically, displayed a lack of awareness of its own rules, regulations and, sometimes, the reality of the world it operates in.

But first, a brief history of the Commission and its predecessors.

State Athletic Commission annual report, 1914. New York State Library.

Regulation of the New York fight scene started in 1911 with the passing of the Frawley Bill. It was not a popular bill, as it was thought to have legitimized the negative pall that settled on the sport. An editor at the New York Times decried the new Commission and its role: “It is, however, one thing to fight for glory or box for amusement…  while it is quite another to get up clubs, so called, the single purpose of which is the attraction of paying crowds to see boys pummel each other with their fists for a scanty wage” (2). 

By 1913, the State sought to contain wrestling in its grasp, promising to  “…raise the standard of the sport in the estimation of many followers of athletic contests who now have no guarantee that many of the scheduled matches are ‘on the level’” (3).

1921 leg index
New York State Legislative Index, 1921. New York State Library.

In 1921, the “State Boxing Commission,” as it was known, was replaced by the Simpson-Brundage State Athletic Commission Bill to rein in and remove the abuses that have marred two good sports” (4) and the New York State Athletic Commission, as it is known today, was formed.

Athletic Commission meeting minutes, June 14, 1921. New York State Archives

A contemporary pundit wrote that “Boxing conditions in New York are pecular [sic]. The “sport” is so mixed with politics that it is hard to separate them. Not only the matchmaking, the control of the “industry,” and the very championships themselves depend largely upon politics…” (5). The mat game (wrestling), which at the time shared promoters (as well as referees, judges and participants) with the fight game (boxing) had its own system of fixes and fixers. Both sports were wrangled under the umbrella of the new commission because only sports unable to control themselves needed state control.”

When the New York State Athletic Commission was created, it was given an immense amount of power. According to its Rules and Regulations:

The commission shall have and hereby is vested with the sole discretion, management, control and jurisdiction over all such boxing, sparring and wrestling matches or exhibition to be conducted, held or given within the state of New York, and no such boxing, sparring or wrestling match or exhibition shall be conducted, held or given within the state except in accordance with the provisions of this act.  (6)

In short, the Athletic Commission could enact and enforce any and all laws pertaining to the ring in the State of New York without the State Legislature’s approval or interference — including the licensing of boxers and wrestlers.

State Athletic Commission Rules and Regulations, 1929. New York State Library

In 1930, the Commission ruled that all professional wrestling matches in the state be deemed “exhibitions.” The decree came from Commissioner William Muldoon (an ex-wrestler who’d “…traveled nearly all over the world and beat all opponents at a time when wrestling had no “trust” to arrange a list of winners” (7)) after watching a card at Madison Square Garden. I saw some good exhibitions but they were merely that. There was a lot of lofty tumbling, which anyone familiar with the sport knows was unnecessary. It was a fine exhibition of physical achievement but at no time was it a real wrestling match” (8).

Athletic Commission meeting minutes, June 28, 1921. New York State Archives.

The Commission’s power grew under Muldoon’s watch. Boxers, wrestlers, judges, referees, promoters, managers, seconds, announcers, and even ushers, ticket takers, and venue security guards had to have the Commission’s seal of approval before working fight night. Prior to hosting a boxing or wrestling contest or exhibition, venues were allowed to obtain temporary group permits covering its employees for that night. All for a fee, of course, as each and every license and permit meant money in the Commission’s coffers.

In wrestling, everything from match time to the holds allowed and forbidden were set in stone by the Commission. The removal of certain actions from a performer’s moveset isn’t just a gripe of the modern wrestling fan.

A 1946 New York State Athletic Commission memorandum circulated among promoters, wrestlers and referees set a stern disapproval ofcertain facts now taking place in wrestling exhibitions” and promised a 15-day license suspension to any wrestler who leaves the ring during a match, “mixes with spectators” or deliberately pushes aside a referee and thus causes the lowering of the dignity of an official of the New York State Athletic Commission.” Such actions, feared the Commission, would incite the crowd in attendance to riot!

If such a riot should occur, the promoter of such exhibition will be held directly responsible to the New York State Athletic Commission.

New York State Archives

This fear of a riot — the notion of agitating the status quo of the existing social order — is what kept women off the mat. Both the literal and figurative fear of feminine encroachment upon the ring, and how the male-dominated sport and its fans in male-dominated society might react to it,  lead to the Commission’s refusal of women applicants and the eventual legal ban on women in the ring, both the three-roped kind for wrestling and the four-roped one for boxing.

Although women had been working fixed boxing and wrestling matches on the vaudeville, burlesque, and carnival circuits, the first battle for licensing came from boxing.

Library of Congress

Mrs. Gus Ruhlin (married to boxer and occasional wrestler Gus Ruhlin) applied for and was denied a “boxing club license,” though officially the reason was due to the glut of existing clubs and not the fact that she was a woman. But that did not stop her from promoting a “prizefight for suffrage” that she said would feature “lady wrestlers.” Without the license, however, she put herself and those on her card at risk of being fined.

New-York Tribune via

The denial of a license meant the denial of legitimacy, the denial of opportunity, and the denial of employment.

In the late 1920s, women were increasingly participating in boxing exhibitions in America and throughout Europe. A French-American woman, Jeanne Le Mar, who boxed in Europe and in 1927 claimed to be the only female boxing champion in the world,” made an attempt to apply for a license in New York. Her lawyer argued that If women can replace men in all sorts of occupations in time of war, and beat them to a frazzle on tennis courts in time of peace, why shouldn’t they be permitted to engage in professional prize-fights?”  Le Mar told an interviewer that There is no law against women boxing professionally… and I don’t see any ground for banning me” (9). She was right — there was no law and there were, outside of social bias, no grounds.

Two African-American women boxers, Emma Maitland and Aurelia Wheeldin, planned to apply for licenses and seek matches against Le Mar if the Commission approved of the French woman’s application (10). Both started as theatrical performers who included boxing in their act, but the women eventually became serious pugilists. A short film on Maitland and Wheeldin can be seen on YouTube.

(For a great read on early black woman boxers, check out Cathy van Ingen’s Seeing What Our Frames Are Seeing:” Seeking Histories on Early Black Female Boxers.)

Neither Le Mar, Maitland nor Wheeldin received New York State boxing licenses.

During the summer of 1934, Vera De Grasse applied for, and was refused, a New York State boxing manager’s license. The Commission, for the first time, went on record as being opposed to women managers, boxers, and wrestlers. 

Athletic Commission meeting minutes, July 27, 1934. New York State Archives

The Commission’s minutes did not include debates or deliberation on the matter, just a simple sentence and nothing more was committed to print for posterity: “On the motion of Commissioner Wear, it is hereby ordered that no license be issued to any females in the future.”

A writer for the New York Herald Tribune called it “an icy blast of disapproval” from the “rajas of ringdom,” (11). 

The rajas’ decree meant that Mildred Burke, the undisputed queen of the ring who traveled from town to town across America taking on all comers while draped in diamonds and gold, never had the opportunity to wrestle inside Madison Square Garden.

No woman would step between the ropes in the most hallowed of halls in all of ringdom until 1972.

The history continues on part two.

(1) M’Geehan, O.W. (1916, March 14). Heard at the sign of the cauliflower. New-York Tribune. Retrieved 1/10/2016 from ProQuest.
(2) Topics of the Times. (1911, May 05). New York Times.  Retrieved 1/10/2016 from ProQuest.
(3) Women barred in speedway race. (1913, April 10). New York Times. Retrieved 1/10/2016 from ProQuest.
(4) Edgren, R. (1921, December 25). Muldoon, square commissioner, puzzles N.Y. San Francisco Chronicle. Retrieved 1/10/2016 from ProQuest.
Fullerton, H. (1922, November 18). Can’t mix boxing and politics in New York. Chicago Daily Tribune. Retrieved 11/8/2015 from ProQuest.
(6) New York (State). 1929. State Athletic Commission rules and regulations governing boxing and wrestling matches
Edgren, R. (1921, December 25). Muldoon, square commissioner, puzzles N.Y. San Francisco Chronicle. Retrieved 1/10/2016 from ProQuest.
Keane, A. W. (1930, April 11), Calling ’em right with Albert W. Keane, sports editor. The Hartford Courant. Retrieved 11/8/2015 from ProQuest.
 Colored girl boxers to challenge Jeanne Le Mar if she gets license. (1927, Jan 05). The New York Amsterdam News. Retrieved 1/10/2016 from ProQuest. 

(11) New York commission will bar women fight managers. (1934, Jul 28). Chicago Daily Tribune. Retrieved 11/8/2015 from ProQuest.

My apologies for the wonky APA style. It’s been a while.



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