City of Anaheim v. Angels Baseball LP
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''City of Anaheim v. Angels Baseball LP'' is a lawsuit filed in
Orange County, California Orange County is located in the Los Angeles metropolitan area in Southern California. As of the 2020 census, the population was 3,186,989, making it the third-most-populous county in California, the sixth-most-populous in the United States, a ...
Superior Court by the city of
Anaheim, California Anaheim ( ) is a city in northern Orange County, California, part of the Los Angeles metropolitan area. As of the 2020 United States Census, the city had a population of 346,824, making it the most populous city in Orange County, the 10th-most ...
against the owners of the
Los Angeles Angels of Anaheim The Los Angeles Angels are an American professional baseball team based in the Los Angeles metropolitan area. The Angels compete in Major League Baseball (MLB) as a member club of the American League (AL) West division. Since 1966, the team h ...
Major League Baseball Major League Baseball (MLB) is a professional baseball organization and the oldest major professional sports league in the world. MLB is composed of 30 total teams, divided equally between the National League (NL) and the American League (AL), ...
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 is a baseball stadium located in Anaheim, California. Since its opening in 1966, it has served as the home ballpark of the Los Angeles Angels of Major League Baseball (MLB), and was also the home stadium to the Los Ange ...
. 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'
Dodger Stadium Dodger Stadium is a baseball stadium in the Elysian Park neighborhood of Los Angeles, California. It is the home stadium of Major League Baseball's Los Angeles Dodgers. Opened in 1962, it was constructed in less than three years at a cost of ...
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 (commonly shortened to SoCal) is a geographic and cultural region that generally comprises the southern portion of the U.S. state of California. It includes the Los Angeles metropolitan area, the second most populous urban a ...
—Major League Baseball's second-largest media market—rather than just
Orange County Orange County most commonly refers to: *Orange County, California, part of the Los Angeles metropolitan area Orange County may also refer to: U.S. counties *Orange County, Florida, containing Orlando *Orange County, Indiana *Orange County, New ...
. 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 Wrigley Field is a Major League Baseball (MLB) stadium on the North Side of Chicago, Illinois. It is the home of the Chicago Cubs, one of the city's two MLB franchises. It first opened in 1914 as Weeghman Park for Charles Weeghman's Chicago ...
in
South Los Angeles South Los Angeles, also known as South Central Los Angeles or simply South Central, is a region in southwestern Los Angeles County, lying mostly within the city limits of Los Angeles, south of downtown. It is "defined on Los Angeles city maps as a ...
(not to be confused with the
Chicago (''City in a Garden''); I Will , image_map = , map_caption = Interactive Map of Chicago , coordinates = , coordinates_footnotes = , subdivision_type = Country , subdivision_name ...
stadium of the same name). They moved to
Dodger Stadium Dodger Stadium is a baseball stadium in the Elysian Park neighborhood of Los Angeles, California. It is the home stadium of Major League Baseball's Los Angeles Dodgers. Opened in 1962, it was constructed in less than three years at a cost of ...
the following season, becoming tenants of the
National League The National League of Professional Baseball Clubs, known simply as the National League (NL), is the older of two leagues constituting Major League Baseball (MLB) in the United States and Canada, and the world's oldest extant professional team ...
's
Los Angeles Dodgers The Los Angeles Dodgers are an American professional baseball team based in Los Angeles. The Dodgers compete in Major League Baseball (MLB) as a member club of the National League (NL) West division. Established in 1883 in the city of Brooklyn ...
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, as they were the only
American League The American League of Professional Baseball Clubs, known simply as the American League (AL), is one of two leagues that make up Major League Baseball (MLB) in the United States and Canada. It developed from the Western League, a minor league ...
team in the state at the time, and moved to the city-owned
Anaheim Stadium Angel Stadium of Anaheim is a baseball stadium located in Anaheim, California. Since its opening in 1966, it has served as the home ballpark of the Los Angeles Angels of Major League Baseball (MLB), and was also the home stadium to the Los Angel ...
in . They would play under this moniker for over 30 seasons.


Anaheim name change

In
The Walt Disney Company The Walt Disney Company, commonly known as Disney (), is an American multinational mass media and entertainment industry, entertainment conglomerate (company), conglomerate headquartered at the Walt Disney Studios (Burbank), Walt Disney Stud ...
acquired a 25% interest in the Angels from the Autrys. The following year, the team changed its name to ''Anaheim Angels'', the result of an agreement between the city and the team to refurbish and downsize Anaheim Stadium after the 1995 departure of the NFL's Los Angeles Rams to
St. Louis St. Louis () is the second-largest city in Missouri, United States. It sits near the confluence of the Mississippi and the Missouri Rivers. In 2020, the city proper had a population of 301,578, while the bi-state metropolitan area, which e ...
. 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 team name, as the NHL's
Mighty Ducks of Anaheim Mighty may refer to: * ''Mighty'' (The Planet Smashers album) * ''Mighty'' (Kristene DiMarco album) * ''The Mighty'' (1929 film), a 1929 American action film *'' The Mighty'', a 1998 comedy-drama film * ''The Mighty'' (comics), a DC Comics title * ...
(now known as the Anaheim Ducks), also owned by Disney, were enfranchised in 1993. Disney acquired 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 billboard magnate from
Arizona Arizona ( ; nv, Hoozdo Hahoodzo ; ood, Alĭ ṣonak ) is a state in the Southwestern United States. It is the 6th largest and the 14th most populous of the 50 states. Its capital and largest city is Phoenix. Arizona is part of the Fou ...
. 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 __notoc__ A wordmark, word mark, or logotype, is usually a distinct text-only typographic treatment of the name of a company, institution, or product name used for purposes of identification and branding. Examples can be found in the graphic iden ...
or halo insignia. 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 is the second-largest metropolitan region in the United States with a population of 18.5 million in 2021, encompassing five counties in Southern California extending from Ventura County in the west to San Bernardino Coun ...
, which comprises the counties of
Los Angeles Los Angeles ( ; es, Los Ángeles, link=no , ), often referred to by its initials L.A., is the List of municipalities in California, largest city in the U.S. state, state of California and the List of United States cities by population, sec ...
, Ventura, Riverside, and
San Bernardino San Bernardino (; Spanish for "Saint Bernardino") is a city and county seat of San Bernardino County, California, United States. Located in the Inland Empire region of Southern California, the city had a population of 222,101 in the 2020 cen ...
, in addition to
Orange County Orange County most commonly refers to: *Orange County, California, part of the Los Angeles metropolitan area Orange County may also refer to: U.S. counties *Orange County, Florida, containing Orlando *Orange County, Indiana *Orange County, New ...
. New owner Moreno believed the new name would help him market the team to the entire
Southern California Southern California (commonly shortened to SoCal) is a geographic and cultural region that generally comprises the southern portion of the U.S. state of California. It includes the Los Angeles metropolitan area, the second most populous urban a ...
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 is a baseball stadium located in Anaheim, California. Since its opening in 1966, it has served as the home ballpark of the Los Angeles Angels of Major League Baseball (MLB), and was also the home stadium to the Los An ...
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 __notoc__ A wordmark, word mark, or logotype, is usually a distinct text-only typographic treatment of the name of a company, institution, or product name used for purposes of identification and branding. Examples can be found in the graphic iden ...
. 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") 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 changed the team's 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 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 Dammann Eisner (born March 7, 1942) is an American businessman and former chairman and chief executive officer (CEO) of The Walt Disney Company from September 1984 to September 2005. Prior to Disney, Eisner was president of rival film st ...
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 The luxury box (or skybox) and club seating constitute the most exclusive class of seating in arenas and stadiums, and generate much higher revenues than regular seating. Club ticketholders often receive exclusive access to an indoor part of th ...
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 Orange County most commonly refers to: *Orange County, California, part of the Los Angeles metropolitan area Orange County may also refer to: U.S. counties *Orange County, Florida, containing Orlando *Orange County, Indiana *Orange County, New ...
city, as well as the mayor of Los Angeles, signed a petition opposing the name change, while the
city council A municipal council is the legislative body of a municipality or local government area. Depending on the location and classification of the municipality it may be known as a city council, town council, town board, community council, rural counc ...
s 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 The National League of Professional Baseball Clubs, known simply as the National League (NL), is the older of two leagues constituting Major League Baseball (MLB) in the United States and Canada, and the world's oldest extant professional team ...
's
Dodgers The Los Angeles Dodgers are an American professional baseball team based in Los Angeles. The Dodgers compete in Major League Baseball (MLB) as a member club of the National League (NL) West division. Established in 1883 in the city of Brooklyn ...
, the NBA's Lakers and
Clippers The Los Angeles Clippers are an American professional basketball team based in Los Angeles. The Clippers compete in the National Basketball Association (NBA) as a member of the Pacific Division in the league's Western Conference. The Clipper ...
, the WNBA's Sparks, the NHL's Kings, and the Arena Football League's Avengers.
Disney The Walt Disney Company, commonly known as Disney (), is an American multinational mass media and entertainment conglomerate headquartered at the Walt Disney Studios complex in Burbank, California. Disney was originally founded on October ...
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 th
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 A court of appeals, also called a court of appeal, appellate court, appeal court, court of second instance or second instance court, is any court of law that is empowered to hear an appeal of a trial court or other lower tribunal. In much of ...
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." And, 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 The American League West is one of Major League Baseball's six divisions. The division has five teams as of the 2013 season, but had four teams from 1994 to 2012, and had as many as seven teams before the 1994 realignment. Although its teams curr ...
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 Allan Huber "Bud" Selig (; born July 30, 1934) is an American baseball executive who currently serves as the Commissioner Emeritus of Baseball. Previously, he served as the ninth Commissioner of Baseball from 1998 to 2015. He initially served as ...
calling the Angels a "model franchise." In 2007, the Angels' name change was the inspiration for the independent minor league
Long Beach Armada The Long Beach Armada were 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 (GBL), which was not affiliated wi ...
baseball team's
tongue-in-cheek The idiom tongue-in-cheek refers to a humorous or sarcastic statement expressed in a serious manner. History The phrase originally expressed contempt, but by 1842 had acquired its modern meaning. Early users of the phrase include Sir Walter Scot ...
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 Thomas John Umberg (born September 25, 1955) is an American politician who serves in the California State Senate. A Democrat, he represents the 34th district, which encompasses parts of northern Orange County and a small portion of Long Beach. ...
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


See also

*
Baseball law Baseball law refers to the various civil statutes, local ordinances, and court decisions pertaining to the game of baseball and its institutions, as distinguished from the Rules of Baseball, which are a private codification of rules governing the i ...
{{Los Angeles Angels of Anaheim Los Angeles Angels of Anaheim Baseball in Los Angeles 2006 in United States case law Baseball law 2006 in baseball California state case law 2006 in sports in California United States contract case law History of Anaheim, California Baseball in Anaheim, California Sports case law Law articles needing an infobox Major League Baseball litigation