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When the Phillies outrighted Domonic Brown off of their 40-man roster, they all but assured themselves that Brown would not return. Brown did have the option to accept a minor league assignment to remain with the Phillies. As it was probably better for Brown and for the Phillies, Brown declined to do so.
Matt Eddy of Baseball America reported the move:
#Phillies OF Domonic Brown elects free agency following his outright off 40-man roster.