City of Anaheim v. Angels Baseball LP

City of Anaheim v. Angels Baseball LP is a lawsuit filed in Orange County, California

Orange County, California

Orange County is a county in the U.S. state of California. Its county seat is Santa Ana. As of the 2010 census, its population was 3,010,232, up from 2,846,293 at the 2000 census, making it the third most populous county in California, behind Los Angeles County and San Diego County...

Superior Court

Superior Courts of California

The Superior Courts of California are the superior courts in the U.S. state of California with general jurisdiction to hear and decide any civil or criminal action which is not specially designated to be heard in some other court or before a government agency...

by the city of Anaheim, California

Anaheim, California

Anaheim is a city in Orange County, California. As of the 2010 United States Census, the city population was about 365,463, making it the most populated city in Orange County, the 10th most-populated city in California, and ranked 54th in the United States...

against the owners of the Los Angeles Angels of Anaheim

Los Angeles Angels of Anaheim

The Los Angeles Angels of Anaheim are a professional baseball team based in Anaheim, California, United States. The Angels are a member of the Western Division of Major League Baseball's American League. The "Angels" name originates from the city in which the team started, Los Angeles...

Major League Baseball

Major League Baseball is the highest level of professional baseball in the United States and Canada, consisting of teams that play in the National League and the American League...

franchise, concerning the team's official name. The lawsuit and a related political and public relations battle sought to reverse the team's official name change from Anaheim Angels to Los Angeles Angels of Anaheim, which the city characterized as a breach of the team's lease on the city-owned Angel Stadium of Anaheim

Angel Stadium of Anaheim

Angel Stadium of Anaheim is a modern-style ballpark located in Anaheim, California. It is the home ballpark to Major League Baseball's Los Angeles Angels of Anaheim of the American League, and was previously home to the NFL's Los Angeles Rams...

. The city was unsuccessful, as both a trial jury and an appellate court ruled in the team's favor.

The Angels franchise was founded as the Los Angeles Angels in 1961 and played under that name until 1965, when it changed its name to California Angels upon its move from Los Angeles

Los Ángeles

Los Ángeles is the capital of the province of Biobío, in the commune of the same name, in Region VIII , in the center-south of Chile. It is located between the Laja and Biobío rivers. The population is 123,445 inhabitants...

' Dodger Stadium

Dodger Stadium

Dodger Stadium, also sometimes called Chavez Ravine, is a stadium in Los Angeles. Located adjacent to Downtown Los Angeles, Dodger Stadium has been the home ballpark of Major League Baseball's Los Angeles Dodgers team since 1962...

to the new Anaheim Stadium (now Angel Stadium of Anaheim). In 1996, the Angels and the city of Anaheim agreed on a new lease that called for the city to fund renovations to Anaheim Stadium, and called for the team's name to contain the name "Anaheim". The following year, the team's official name changed again to Anaheim Angels.

In 2003, the team was sold to Arturo "Arte" Moreno. Less than two years later, the team announced it was changing its name to Los Angeles Angels of Anaheim, an attempt to market the team as being from Southern California

Southern California

Southern California is a megaregion, or megapolitan area, in the southern area of the U.S. state of California. Large urban areas include Greater Los Angeles and Greater San Diego. The urban area stretches along the coast from Ventura through the Southland and Inland Empire to San Diego...

—Major League Baseball's second-largest media market—rather than just Orange County

Orange County, California

. The "of Anaheim" phrase was included to comply with the terms of the 1996 lease. Anaheim city officials immediately denounced the change, characterizing it as a breach of the lease, even though it was in technical compliance. Likewise, many fans denounced the change, as many Orange County residents consider Orange County to have its own identity separate from Los Angeles.

A preliminary injunction

Preliminary injunction

A preliminary injunction, in equity, is an injunction entered by a court prior to a final determination of the merits of a legal case, in order to restrain a party from going forward with a course of conduct or compelling a party to continue with a course of conduct until the case has been decided...

filed by the city seeking to immediately reverse the name change was unsuccessful, and the Angels began playing under the new name for the 2005 season

2005 Major League Baseball season

Click on any series score to link to that series' page.Higher seed had home field advantage during Division Series and League Championship Series.The American League champion had home field advantage during the World Series as a result of the AL victory in the 2005 All-Star...

Autry/Disney ownership

The present-day Angels franchise began play as the Los Angeles Angels in . Owned by actor Gene Autry

Gene Autry

Orvon Grover Autry , better known as Gene Autry, was an American performer who gained fame as The Singing Cowboy on the radio, in movies and on television for more than three decades beginning in the 1930s...

and his wife Jackie

Jackie Autry

Jackie Autry, is the former owner of the Los Angeles Angels of Anaheim and widow of singer, actor and businessman Gene Autry...

, they played their inaugural season at Wrigley Field

Wrigley Field (Los Angeles)

Wrigley Field was a ballpark in Los Angeles, California which served as host to minor league baseball teams in the region for over 30 years, and was the home park for the Los Angeles Angels of the Pacific Coast League as well as a current major league team, the later Los Angeles Angels, in their...

in South Los Angeles

South Los Angeles

South Los Angeles, often abbreviated as South L.A. and formerly South Central Los Angeles, is the official name for a large geographic and cultural portion lying to the southwest and southeast of downtown Los Angeles, California. The area was formerly called South Central, and is still widely known...

(not to be confused with the Chicago

Chicago

Chicago is the largest city in the US state of Illinois. With nearly 2.7 million residents, it is the most populous city in the Midwestern United States and the third most populous in the US, after New York City and Los Angeles...

stadium of the same name

Wrigley Field

Wrigley Field is a baseball stadium in Chicago, Illinois, United States that has served as the home ballpark of the Chicago Cubs since 1916. It was built in 1914 as Weeghman Park for the Chicago Federal League baseball team, the Chicago Whales...

). They moved to Dodger Stadium

Dodger Stadium

the following season, becoming tenants of the National League

National League

The National League of Professional Baseball Clubs, known simply as the National League , is the older of two leagues constituting Major League Baseball, and the world's oldest extant professional team sports league. Founded on February 2, 1876, to replace the National Association of Professional...

's Los Angeles Dodgers

Los Angeles Dodgers

The Los Angeles Dodgers are a professional baseball team based in Los Angeles, California. The Dodgers are members of Major League Baseball's National League West Division. Established in 1883, the team originated in Brooklyn, New York, where it was known by a number of nicknames before becoming...

for four seasons. During the season, Gene Autry struck a deal with the suburb

Suburb

The word suburb mostly refers to a residential area, either existing as part of a city or as a separate residential community within commuting distance of a city . Some suburbs have a degree of administrative autonomy, and most have lower population density than inner city neighborhoods...

an city of Anaheim

Anaheim, California

on a new stadium for the Angels. The team changed its name to California Angels late in the season, as they were the only American League

American League

The American League of Professional Baseball Clubs, or simply the American League , is one of two leagues that make up Major League Baseball in the United States and Canada. It developed from the Western League, a minor league based in the Great Lakes states, which eventually aspired to major...

team in the state at the time, and moved to the city-owned Anaheim Stadium

Angel Stadium of Anaheim

in . They would play under this moniker for over 30 seasons.

In The Walt Disney Company

The Walt Disney Company

The Walt Disney Company is the largest media conglomerate in the world in terms of revenue. Founded on October 16, 1923, by Walt and Roy Disney as the Disney Brothers Cartoon Studio, Walt Disney Productions established itself as a leader in the American animation industry before diversifying into...

acquired a 25% interest in the Angels from the Autrys. The following year

1997 in baseball

-Major League Baseball:*World Series: Florida Marlins over Cleveland Indians ; Liván Hernández, MVP*American League Championship Series MVP: Marquis Grissom**American League Division Series*National League Championship Series MVP: Liván Hernández...

, the team changed its name again to Anaheim Angels, the result of an agreement between the city and the team to refurbish and downsize Anaheim Stadium after the 1994 departure of the NFL's

National Football League

The National Football League is the highest level of professional American football in the United States, and is considered the top professional American football league in the world. It was formed by eleven teams in 1920 as the American Professional Football Association, with the league changing...

Los Angeles Rams

St. Louis Rams

The St. Louis Rams are a professional American football team based in St. Louis, Missouri. They are currently members of the West Division of the National Football Conference in the National Football League . The Rams have won three NFL Championships .The Rams began playing in 1936 in Cleveland,...

to St. Louis

St. Louis, Missouri

St. Louis is an independent city on the eastern border of Missouri, United States. With a population of 319,294, it was the 58th-largest U.S. city at the 2010 U.S. Census. The Greater St...

. One clause of the new lease required that the team name contain the name "Anaheim". There was precedent for the name "Anaheim" in a major professional sports

Major professional sports leagues of the United States and Canada

The major professional sports leagues, or simply major leagues, in the United States and Canada are the highest professional competitions in team sports...

team name, as the NHL's

National Hockey League

The National Hockey League is an unincorporated not-for-profit association which operates a major professional ice hockey league of 30 franchised member clubs, of which 7 are currently located in Canada and 23 in the United States...

Mighty Ducks of Anaheim

Anaheim Ducks

The Anaheim Ducks are a professional ice hockey team based in Anaheim, California, USA. They are members of the Pacific Division of the Western Conference of the National Hockey League...

(now known as the Anaheim Ducks), also owned by Disney, were enfranchised in 1993. Disney would acquire the remaining share of the team in , less than a year after Gene Autry's death.

Moreno ownership

Early in the season, Disney sold the team to Arturo "Arte" Moreno, a fourth-generation Mexican American

Mexican American

Mexican Americans are Americans of Mexican descent. As of July 2009, Mexican Americans make up 10.3% of the United States' population with over 31,689,000 Americans listed as of Mexican ancestry. Mexican Americans comprise 66% of all Hispanics and Latinos in the United States...

billboard

Billboard

Billboard is a weekly American magazine devoted to the music industry, and is one of the oldest trade magazines in the world. It maintains several internationally recognized music charts that track the most popular songs and albums in various categories on a weekly basis...

magnate from Arizona

Arizona

Arizona ; is a state located in the southwestern region of the United States. It is also part of the western United States and the mountain west. The capital and largest city is Phoenix...

. Though he vowed to keep the team in Anaheim, starting in the 2004 season, all references to Anaheim began disappearing from the Angels players' uniforms, officially licensed merchandise, web site, ticket media, and promotional materials, and were replaced with "Angels", "Angels Baseball", or the Angels' wordmark

Wordmark

A wordmark, word mark or logotype is a standardized text logo or graphic representation of the name of a company, institution, or product name used for purposes of identification and branding. A wordmark is usually a distinct text-only typographic treatment as can be found in the graphic identities...

or halo insignia

Insignia

Insignia or insigne pl -nia or -nias : a symbol or token of personal power, status or office, or of an official body of government or jurisdiction...

.

On January 3, 2005 the Angels announced that the club's official name was being changed to Los Angeles Angels of Anaheim. In its official announcement, team spokesmen pointed out the Angels had been originally created as the American League's representative of the Greater Los Angeles area

Greater Los Angeles Area

The Greater Los Angeles Area, or the Southland, is a term used for the Combined Statistical Area sprawled over five counties in the southern part of California, namely Los Angeles County, Orange County, San Bernardino County, Riverside County and Ventura County...

, which comprises the counties of Los Angeles

Los Angeles County, California

Los Angeles County is a county in the U.S. state of California. As of 2010 U.S. Census, the county had a population of 9,818,605, making it the most populous county in the United States. Los Angeles County alone is more populous than 42 individual U.S. states...

, Ventura

Ventura County, California

Ventura County is a county in the southern part of the U.S. state of California. It is located on California's Pacific coast. It is often referred to as the Gold Coast, and has a reputation of being one of the safest populated places and one of the most affluent places in the country...

, Riverside

Riverside County, California

Riverside County is a county in the U.S. state of California. One of 58 California counties, it covers in the southern part of the state, and stretches from Orange County to the Colorado River, which forms the state border with Arizona. The county derives its name from the city of Riverside,...

, and San Bernardino

San Bernardino County, California

San Bernardino County is a county in the U.S. state of California. As of the 2010 census, the population was 2,035,210, up from 1,709,434 as of the 2000 census...

, in addition to Orange County

Orange County, California

.

New owner Moreno believed the new name would help him market the team to the entire Southern California

Southern California

region rather than just Orange County, thereby tapping into Major League Baseball's second largest media market. The of Anaheim phrase was included in the official name to comply with a provision of the team's lease at Angel Stadium

Angel Stadium of Anaheim

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

Wordmark

. The Dodgers, not wanting to give up any of its market share to the Angels, countered with their own billboard campaign, featuring the slogan “LA Baseball” (with "LA" depicted in the team's insignia), and putting Los Angeles Dodgers of Los Angeles on special giveaway merchandise for Opening Day 2005.

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

Orange Curtain

The Orange Curtain is a term that refers to the border between Orange County and Los Angeles County in the U.S. state of California. It is a sometimes derogatory, sometimes lighthearted term, that is used to describe Orange County's more conservative and suburban population as compared to the more...

") 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".

Lawsuit

Anaheim Mayor Curt Pringle

Curt Pringle

Curtis L. "Curt" Pringle , is a politician from the U.S. state of California. Pringle, a Republican, a onetime Speaker of the California State Assembly, former Mayor of Anaheim, California and former Chairman of the California High Speed Rail Authority, today runs his own public relations and...

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

Michael Eisner

Michael Dammann Eisner is an American businessman. He was the chief executive officer of The Walt Disney Company from 1984 until 2005.-Early life:...

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 boycott

Boycott

A boycott is an act of voluntarily abstaining from using, buying, or dealing with a person, organization, or country as an expression of protest, usually for political reasons...

ed the city's luxury suite at Angel Stadium, including during the Angels' 2005 playoff run

2005 Los Angeles Angels of Anaheim season

The Los Angeles Angels of Anaheim 2005 season was the franchise's 45th since its inception. The regular season ended with a record of 95-67, resulting in the Angels winning the American League West division title for the second consecutive season, its fifth in franchise history.In the postseason,...

, 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

Orange County, California

city, as well as the mayor of Los Angeles, signed a petition opposing the name change, while the city council

City council

A city council or town council is the legislative body that governs a city, town, municipality or local government area.-Australia & NZ:Because of the differences in legislation between the States, the exact definition of a City Council varies...

s of Anaheim, Irvine

Irvine, California

Irvine is a suburban incorporated city in Orange County, California, United States. It is a planned city, mainly developed by the Irvine Company since the 1960s. Formally incorporated on December 28, 1971, the city has a population of 212,375 as of the 2010 census. However, the California...

, 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

National League

Dodgers

Los Angeles Dodgers

, the NBA's

National Basketball Association

The National Basketball Association is the pre-eminent men's professional basketball league in North America. It consists of thirty franchised member clubs, of which twenty-nine are located in the United States and one in Canada...

Lakers

Los Angeles Lakers

The Los Angeles Lakers are an American professional basketball team based in Los Angeles, California. They play in the Pacific Division of the Western Conference in the National Basketball Association...

and Clippers

Los Angeles Clippers

The Los Angeles Clippers are a professional basketball team based in Los Angeles, California, United States. They play in the Pacific Division of the Western Conference of the National Basketball Association...

, the WNBA's

Women's National Basketball Association

The Women's National Basketball Association is a women's professional basketball league in the United States. It currently is composed of twelve teams. The league was founded on April 24, 1996 as the women's counterpart to the National Basketball Association...

Sparks

Los Angeles Sparks

The Los Angeles Sparks is a professional basketball team based in Los Angeles, California, playing in the Western Conference in the Women's National Basketball Association . The team was founded before the league's inaugural 1997 season began...

, the NHL's

National Hockey League

Kings

Los Angeles Kings

The Los Angeles Kings are a professional ice hockey team based in Los Angeles, California. They are members of the Pacific Division of the Western Conference of the National Hockey League...

, and the Arena Football League's Avengers

Los Angeles Avengers

The Los Angeles Avengers was an Arena Football League team based in Los Angeles, California from 2000 through 2008. They folded on April 19, 2009.-History:...

. Disney

The Walt Disney Company

and the city of Los Angeles filed amicus curiae
Amicus curiae
An amicus curiae is someone, not a party to a case, who volunteers to offer information to assist a court in deciding a matter before it...

papers in Orange County Superior Court supporting Anaheim's position in its lawsuit against the team.

The city also sought a preliminary injunction

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 judgment, 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.

Appeal

On February 26, 2007, the city of Anaheim appeal

Appeal

An appeal is a petition for review of a case that has been decided by a court of law. The petition is made to a higher court for the purpose of overturning the lower court's decision....

ed the jury's decision, citing some testimony that it wanted to present but was not heard in the jury trial, and sought to recoup an estimated $

United States dollar

The United States dollar , also referred to as the American dollar, is the official currency of the United States of America. It is divided into 100 smaller units called cents or pennies....

7 million in court costs. On December 20, 2008, a state appellate court

Appellate court

An appellate court, commonly called an appeals court or court of appeals or appeal court , is any court of law that is empowered to hear an appeal of a trial court or other lower tribunal...

issued a split decision denying the city's appeal and refusing to either set aside the jury's verdict or order the team to pay for the city's court costs. On January 13, 2009, Anaheim's city council voted not to further appeal the court's decisions, bringing a conclusion to the legal battle.

Aftermath

Despite the legal victory, the team only uses its full name on official press releases and its website, and continues to market itself without direct reference to location wherever possible. Neither "Los Angeles" nor "Anaheim" appears on the team's uniforms or officially licensed merchandise or promotional materials; "Angels" or "Angels Baseball" are used instead. Major League Baseball and the national media have recognized the name change from the beginning, and team ownership correctly predicted that the national media and the general public would drop "of Anaheim" out of convenience and refer to the team as simply the "Los Angeles Angels."

Despite the prolonged legal battle, organized fan resistance to the new name subsided long before the appellate court ruling.

The name controversy and the city's suit and boycott did little to quell fan enthusiasm for the team, as Angel Stadium consistently drew over 3.3 million fans through its gates each season from 2004 to 2008. It also had little to no impact on the team's on-field performance — they won four American League West

American League West

The American League West is one of three divisions in Major League Baseball's American League. The division currently has four teams, but it has had as many as seven teams before the 1994 realignment. Although its teams currently only reside along the west coast and in Texas, historically the...

division titles over the same timespan, marking the most successful era in franchise history. The controversy also did little to negatively impact the perception of team ownership around the league, as evidenced by the Angels being selected to host the 2010 All-Star Game

2010 Major League Baseball All-Star Game

The 2010 Major League Baseball All-Star Game was the 81st midseason exhibition between the All-Stars of the American League and the National League , the two leagues comprising Major League Baseball...

, with MLB Commissioner

Commissioner of Baseball

The Commissioner of Baseball is the chief executive of Major League Baseball and its associated minor leagues. Under the direction of the Commissioner, the Office of the Commissioner of Baseball hires and maintains the sport's umpiring crews, and negotiates marketing, labor, and television contracts...

Bud Selig

Allan Huber "Bud" Selig is the ninth and current Commissioner of Major League Baseball, having served in that capacity since 1992 as the acting commissioner, and as the official commissioner since 1998...

calling the Angels a "model franchise."

In 2007, the Angels' name change was the inspiration for the independent minor league Long Beach Armada

Long Beach Armada

The Long Beach Armada was an independent professional baseball team based in Long Beach, California, in the United States. The Armada was a member of the North Division of the now-defunct Golden Baseball League, which was not affiliated with either Major League Baseball or Minor League Baseball...

baseball team's tongue-in-cheek

Tongue-in-cheek

Tongue-in-cheek is a phrase used as a figure of speech to imply that a statement or other production is humorously intended and it should not be taken at face value. The facial expression typically indicates that one is joking or making a mental effort. In the past, it may also have indicated...

name change to the Long Beach Armada of Los Angeles of California of the United States of North America Including Barrow, Alaska
Barrow, Alaska
Barrow is the largest city of the North Slope Borough in the U.S. state of Alaska. It is one of the northernmost cities in the world and is the northernmost city in the United States of America, with nearby Point Barrow being the nation's northernmost point. Barrow's population was 4,212 at the...

.

The "Truth in Sports Advertising Act"

On February 22, 2005, California state assemblyman

California State Assembly

The California State Assembly is the lower house of the California State Legislature. There are 80 members in the Assembly, representing an approximately equal number of constituents, with each district having a population of at least 420,000...

Tom Umberg

Thomas John Umberg is a U.S. politician, who was a Democrat in the California State Assembly, representing the 69th District.-Military service and family:...

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

California State Senate

The California State Senate is the upper house of the California State Legislature. There are 40 state senators. The state legislature meets in the California State Capitol in Sacramento. The Lieutenant Governor is the ex officio President of the Senate and may break a tied vote...

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.

External links

City of Anaheim v. Superior Court, no. G037202, (Cal. App. June 27, 2005)(Order denying writ to vacate denial of preliminary injunction)
California Court of Appeal case summary
Copy of City of Anaheim's complaint (PDF) from Anaheim.net

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