City of Anaheim v. Angels Baseball LP

thumb|right|300px|[[Angel Stadium of Anaheim. City of Anaheim v. Angels Baseball LP was a legal case over the terms of the team's lease of the city-owned stadium.]]

City of Anaheim v. Angels Baseball LP is a lawsuit filed in Orange County, California Superior Court by the city of Anaheim, California, against the owners of the Los Angeles Angels of Anaheim Major League Baseball 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. 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 was changing its name to California Angels in preparation for its move from Los Angeles' Dodger Stadium to the new Anaheim Stadium (now Angel Stadium of Anaheim) the following year. 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—Major League Baseball's second-largest media market—rather than just Orange County. 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. 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 filed by the city seeking to immediately reverse the name change was unsuccessful, and the Angels began playing under the new name for the 2007 season.

Background

Autry ownership

The present-day Angels franchise began play as the Los Angeles Angels in . Owned by actor Gene Autry and his wife Jackie, they played their inaugural season at Wrigley Field in South Los Angeles (not to be confused with the Chicago stadium of the same name). They moved to Dodger Stadium the following season, becoming tenants of the National League's Los Angeles Dodgers for four seasons. During the season, Gene Autry struck a deal with the suburban city of Anaheim on a new stadium for the Angels. The team changed its name to California Angels late in the season, The following year, the team changed its name to Anaheim Angels,

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, which comprises the counties of Los Angeles, Ventura, Riverside, and San Bernardino, in addition to Orange County. 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), 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 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 appealed 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 US$7 million in court costs. On December 20, 2008, a state appellate court 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 used the full name on official press releases and website, and continued 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." Prior to the 2016 season, the Angels officially dropped "of Anaheim" from their name.

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 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, with MLB Commissioner Bud Selig calling the Angels a "model franchise."

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.

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 have required the Angels to disclose on all tickets and promotional materials that the team's home is Anaheim, not Los Angeles, unless Anaheim or Orange County exempted the franchise from the requirement. 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.

References

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