City of Anaheim v. Angels Baseball LP
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City of Anaheim v. Angels Baseball LP is an ongoing legal case between the city of 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.
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[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 the city-owned Anaheim Stadium in 1966.
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 after the departude of the Los Angeles Rams to St. Louis. 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 aging Disneyland theme park located in Anaheim.
[edit] Key Players
[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. Starting in the 2004 season, after Moreno's purchase of the team, all references to Anaheim began disappearing from the Angels players' uniforms, officially licensed merchandise, web site, ticket media, promotional material, and Angel Stadium scoreboards and marquees, and were replaced with "Angels", "Angels Baseball", or the Angels' halo logo. Then, 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. At the same time they announced the name change, 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 giveaway merchandise for Opening Day 2005.
[edit] Fan response
The name change upset some fans from Orange County who did not wish to be associated with Los Angeles. It has been claimed that a cultural divide (the "Orange Curtain") exists between Orange County and Los Angeles; some fans suggested that Moreno, an Arizona native, did not take into account the alleged animosity between residents of the two counties when he attempted to restore the team's original name. Some fans wished for either the name to stay the same, or even for an alternate rename to the "Orange County Angels." Some fans made and sold unlicensed merchandise with messages such as "We are not LA" and "Anaheim Angels of Anaheim".
[edit] The "Truth in Sports Advertising Act"
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, effectively killing the bill.
[edit] Bringing the Case to Trial
Anaheim Mayor Curt Pringle and other city officials asserted that the name change violated the spirit of the lease clause, even if it was 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. Concurrently, city politicians boycotted the city's luxury suite at Angel Stadium, including during the Angels' 2005 playoff run, opting instead to donate game tickets in the suite to various charities. A trial, initially set for November 7, 2005 was postponed until January 9, 2006.
In addition to the lawsuit brought by the city of Anaheim, the mayors of every Orange County city, as well as the mayor of Los Angeles, signed a petition opposing the name change, while the city councils of Anaheim, Irvine, and Los Angeles adopted formal resolutions opposing the name change. The Los Angeles resolution specifically stated that the city only recognizes professional sports teams bearing the name "Los Angeles" as those whose home facilities are within the Los Angeles city limits, including the National League's Dodgers, the NBA's Lakers and Clippers, the WNBA's Sparks, the NHL's Kings, and the Arena Football League's Avengers. Disney and the city of Los Angeles filed amicus curiae papers in Orange County Superior Court supporting Anaheim's position in its lawsuit against the team.
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] Appeal
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. The appeal was officially filed on February 26, 2007. [1]
[edit] After the Jury Trial
The Angels have continued to market themselves without direct reference to their location whenever possible. Neither "Los Angeles" nor "Anaheim" appears on the team's uniforms, and Angels are not referred to as "Los Angeles" by the Angel Stadium ballpark announcer nor by the Angels' television and radio broadcasters, who use "Angels" or "Angels Baseball" in its place.
On official press releases, and on the team's website, the entire name "Los Angeles Angels of Anaheim" is used. When Major League Baseball uses location to identify a team, it refers to the Angels as "Los Angeles," as do MLB's member teams and many sportscasters.[2]
Although an appeal filed by the city's attorneys is still pending, organized fan resistance to the new name has subsided.[3][4]
In 2007, the Angels' name change was the inspiration for the independent minor league Long Beach Armada baseball team's tongue-in-cheek name change to the Long Beach Armada of Los Angeles of California of the United States of North America Including Barrow, Alaska.[5]
[edit] External links
[edit] References
- ^ The Biz of Baseball, "City of Anaheim Files Appeal in Angels Lawsuit", February 27, 2007
- ^ http://www.ballparksofbaseball.com/nl/wrig910.JPG
- ^ Orange County Register: "Extra innings for Angels suit" May 31, 2006
- ^ Cal State Fullerton: "Q&A: Angels Baseball Needs to Both Covet and Trust Fans", April 7, 2005
- ^ OurSportsCentral.com, "Long Beach Armada Changes Official Name"
