City of Anaheim v. Angels Baseball LP

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City of Anaheim v. Angels Baseball LP is an ongoing legal case between Anaheim, California and the partnership that owns the Angels baseball club, Angels Baseball LP, over the team's official name. The lawsuit and a related political and public relations battle were sparked by the partnership's decision in January 2005 to change the team's name from Anaheim Angels to Los Angeles Angels of Anaheim.

1 History of the Case
2 After the Jury Trial
3 The "Truth in Sports Advertising Act"
4 Reference

[edit] History of the Case

[edit] Pre Arte Moreno

The team joined the American League in 1961 as the Los Angeles Angels, playing in Los Angeles at Wrigley Field. They moved to Dodger Stadium in 1962. During the 1965 season, the team changed its name to the California Angels, moving to Anaheim Stadium in 1966. The stadium was and is owned by the City of Anaheim.

The team changed its name again, to the Anaheim Angels, in 1997, the result of an agreement between the city and the Angels to refurbish and downsize Anaheim Stadium. One clause of the new lease required that the team name "include the name Anaheim therein." At the time, the Angels were partly owned and effectively controlled by The Walt Disney Company which had a vested interest in promoting Anaheim as a so-called "destination city." Disney was in the process also of refurbishing its ageing Disneyland theme park located in Anaheim.

[edit] Arte Moreno Purchases the Team

The team was sold in 2003 to Angels Baseball, L.P., a limited partnership headed by Arturo "Arte" Moreno. During 2004, it was noted by many observers that the new ownership was downplaying or removing "Anaheim" from team uniforms, merchandise, and publications. On January 3, 2005 the Angels announced that they would change the name of the club to the Los Angeles Angels of Anaheim. Team spokesmen pointed out that from its inception, the Angels had been granted the American League's territorial rights by Major League Baseball to the Counties of Los Angeles, Ventura, Riverside, and San Bernardino in addition to Orange County.

The inclusion of Los Angeles reflects the original expansion name and returns the Angels as Major League Baseball's American League representative in the Greater Los Angeles territory.

— Angels' 2005 media guide

New owner Moreno believed the new name would help him market the team to the entire Southern California region rather than just Orange County. The of Anaheim phrase was included in the official name to comply with a provision of the team's lease at Angel Stadium which requires that the team's name "include the name Anaheim therein", although it was correctly anticipated that the team would be referred to as simply the "Los Angeles Angels" by the media and the majority of the public.

[edit] Bringing the Case to Trial

Anaheim Mayor Curt Pringle and other city officials countered that the name change violated the spirit of the lease clause, even if in technical compliance. They argued that a name change was a major bargaining chip in negotiations between the city and Disney, and that the wording of the clause was merely to allow Disney some "wiggle room" in selecting the team name (Disney chairman Michael Eisner reportedly considered naming the team the Mighty Angels of Anaheim). They further argued that the city would never have agreed to the new lease without the name change, because the new lease required that the city partially fund the stadium's renovation while reducing annual revenue for the city. Anaheim sued Angels Baseball L.P. in Orange County Superior Court, seeking monetary damages and a restoration of the Anaheim Angels name. A trial, initially set for November 7, 2005 was postponed until January 9, 2006.

The city also sought a preliminary injunction to immediately reverse the name change in advance of the trial, which was rejected by the superior court judge. The city appealed the judge's ruling to the Court of Appeal, Fourth District, which granted an unusual writ moving the city's case to the top of the docket and held a hearing on March 28, 2005. Though a ruling had been anticipated by April 7, 2005 the three judges of the appellate court merely urged the city and the team to work towards a settlement prior to trial. The appellate court ruled against Anaheim's request for an injunction on June 27, 2005.

The case proceeded to jury trial on January 9, 2006, and on February 9, 2006, the jury found in favor of the team, determining that the Los Angeles Angels of Anaheim name was in compliance with the lease, and thus denying the city any monetary compensation. Both citing the jury verdict finding the team in compliance and noting that his own conclusion agreed with that judgement, on March 2, 2006, the judge in the case formally denied the city's request to force the team to restore the Anaheim Angels name.

[edit] After the Jury Trial

The name issue resolved, the Angels aggressively marketed themselves to Los Angeles, buying space on nearly 500 billboards in the area that read simply "City of ANGELS" in the team's wordmark. The Dodgers countered with their own billboard campaign, featuring the slogan “LA Baseball”, and putting "Los Angeles Dodgers of Los Angeles" on special give away merchandise for Opening Day 2005.

The Los Angeles Dodgers had referred to their neighbor as the Anaheim Angels when they first changed their name to Los Angeles Angels, but once the case was settled, they began, like other teams, to call them the Los Angeles Angels of Anaheim.

On May 30, 2006, the city of Anaheim decided to appeal the jury's decision. It is asking the Angels to recoup its court costs, which it estimates at $7 million. Also, city officials cited some testimony that it wanted to present but was not heard.¹ The appeal was officially filed on February 26, 2007. The Angels will not file a response until June, and a decision is not expected before the end of the 2007 baseball season. [1]

[edit] The "Truth in Sports Advertising Act"

In a related matter, on February 22, 2005, California state assemblyman Tom Umberg introduced a truth in advertising bill (AB 1041) in the State Assembly. If signed into law, the "Truth in Sports Advertising Act" would require the Angels to disclose on all tickets and promotional materials that the team's home is Anaheim, not Los Angeles. On May 16, 2005, the bill passed the California Assembly by a margin of 52-17 and was sent to the California State Senate where, on May 26, 2005, it was referred to the Business, Professions and Economic Development Committee.

State Senate hearings scheduled on June 7 and June 27, 2005 were cancelled at the request of Assemblyman Umberg. On July 11, 2005, the hearing was postponed indefinitely by the Senate committee.