Jury Sides with Angels in Name-Change Dispute

A jury has decided that the Angels did not violate their lease agreement with the city of Anaheim when they adopted the moniker "Los Angeles Angels of Anaheim." The deliberations seemed to turn on the meaning of the five-word requirement in the contract that the team name "include the name Anaheim therein." The nine jurors that voted in the team's favor said the language is clear on its face and not violated by the team's actions. A few jurors said that if the city wanted to ensure that Anaheim was the only locale in the team name, the contract should have said so. (Yoshino & McKibben, "Anaheim Strikes Out Against Angels," LA Times, 02/10/06; Goffard, "Key Word is 'Include' for Angel-Anaheim Jury," LA Times, 02/10/06; Law Blog, 02/10/06).

As the jury has spoken, the chance of a successful appeal seems remote. Certainly, the city's lawyers wish they could go back and put in the specific language. And I didn't hear the evidence presented, so perhaps that language was proposed and rejected during the negotiations. However, it seems that the Angels at the very least violated the spirit of the bargain -- in the environment in which the lease was negotiated, team names included one geographic location and one nickname. The city clearly wanted the team name to include Anaheim so that its constant mention would bring additional attention to the city. Under the current name, the team is known as "LA," not "Anaheim." The long name may satisfy the letter of the contract, but should contracts be read this literally?

Posted in: