In 1909, racing in New York was shut down due to the Hart–Agnew Executive Liability Act, an anti-gambling bill. Therefore, Joyner relocated to England and took several horses with him, including Fair Play.
Due to the Hart–Agnew Executive Liability Act of 1909, which prohibited gambling in New York, racing was shut down.  Joyner then moved to England and brought along several horses, including Fair Play.