It depends on the situation. If the number of players trying out is significantly larger than tbe number of available spots, then making the JV team as a sophomore is arguably easier than making the frosh team. Here's why: In the freshman tryouts, there will be a handfull of players who will obviously make the team. Most of the rest will have a limited amount of time to catch the coaches' attention, and there is a fairly large element of chance in who makes the team.
In the second year, some of the stud players will go directly to varsity, and some will have amply convinced the coaches (and perhaps themselves) that they aren't really baseball material. Many of those cut from freshman tryouts won't try out again for the JV team. And those that do will get a pretty good look, because there will be a much smaller pool for the coaches to look at. So a player who doesn't get discouraged, works hard, and has at least reasonable ability stands a good chance of making the JV team.
In my opinion, "works hard" means both practice and playing competitive baseball at least through the summer.
