Law Religion Culture Review

Exploring the intersections of law, religion and culture. Copyright by Richard J. Radcliffe. All rights reserved.

Friday, January 21, 2005

It's a Matter of Interpretation, Part IV.

These legal issues of interpretation crop up just about everywhere. Today's sports page provides yet another example. Check out the following story in the Los Angeles Times about whether the Angels' 1996 lease with the City of Anaheim allows them to change their name to the "Los Angeles Angels of Anaheim". (Of course, for those who know Spanish, this translates as, The Angels Angels of Anaheim.)

"With five words at issue in determining whether the Angels legally can add Los Angeles to their name, the man who negotiated the contract on behalf of the Walt Disney Co. said Thursday the disputed words were designed 'to give Anaheim prominence … so that Anaheim would be publicized when the baseball team was publicized.'" (B. Shaikin, "Anaheim Filing Cites Name Value", Los Angeles Times, p. D4.)

"The Angels argue that a clause requiring the team name to 'include the name Anaheim therein' permits them to play as the Los Angeles Angels of Anaheim. (Id.) Conversely, the City "had based its case on what the parties intended.... (Id.; emphasis added.) On this basis, the City tried to block the name change in court.

"In a court declaration Thursday, then-Angel president Tony Tavares said Disney Chairman Michael Eisner had not decided whether to use 'Anaheim Angels' or 'Angels of Anaheim'... but had 'no intention of including, or reserving the right to include, two geographic names in the team name.'" (Id.; emphasis added.)

In other words, the City argues that "original intent" should govern the interpretation of the legal document at issue. The Angels, at least in this case, prefer the "plain language" or "textualist" view. "The Angels have filed motions to throw out similar declarations from city negotiators and are expected to file another to throw out the one from Taveres, arguing that the lease speaks for itself and the court need not consider interpretations or explanations." (Id.; emphasis added.)

The Orange County Superior Court, sitting in Santa Ana, California, evidently agreed with the City's approach because the court today denied the City's request for an injunction barring the name change. The court ruled that Anaheim did not establish that it would probably prevail at the time of trial.