Los Angeles Memorial Coliseum Commission v. National Football League

634 F.2d 1197 (9th Cir. 1980)

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Nature of the Case

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Facts

D is an unincorporated association of 28 member teams, each located in a designated metropolitan area where its 'home games' are played. The League's Constitution and Bylaws provide that most important decisions must be approved by a vote of three-fourths of the owners of the member teams. Section 4.3, the rule involved here, requires a three-fourths vote of team owners before any member club may transfer the location of its franchise or playing site to a different city. In July 1978 the Los Angeles Rams football team announced its intention to move from the Los Angeles Coliseum where it had played since 1946 to Anaheim Stadium in Orange County. P began to seek a replacement team. It perceived sections 4.3 and 3.1 as potential obstacles to its attainment of a new tenant either through a new franchise or relocation of an existing one. P brought an antitrust action against the D and its member teams under Section 16 of the Clayton Act, 15 U.S.C. § 26, to enjoin enforcement of these provisions, charging that they violate Sections 1 and 2 of the Sherman Act, 15 U.S.C. §§ 1 and 2. In February 1979 the district court denied the P's motion for partial summary judgment and dismissed the complaint for lack of standing, with leave to amend. After filing an amended complaint, P moved in January 1980 for a preliminary injunction to restrain Ds from invoking section 4.3 or taking other action specifically to prevent transfer of the Oakland Raiders' home site to the Los Angeles Coliseum. The district court granted the P's motion and entered an order enjoining defendants from enforcing section 4.3, as then 'currently written,' to prevent the Raiders or any other NFL team from transferring the location of its home games to P. D appealed. The League eventually took a formal vote of its members which disapproved the transfer by 22 against, none in favor and five abstaining.