Law Religion Culture Review

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

Tuesday, March 01, 2005

It's a Matter of Interpretation, Part IX.

We've been covering the baseball Angels' dispute with the City of Anaheim as a subset of our larger series about rules of interpretation in legal and bibilical texts. (See, e.g., February 17 and 19, 2005, posts.)

The City has appealed (technically, filed a petition for a writ) the denial of its application for a preliminary injunction.

According to the City's papers filed yesterday with the Fourth District Court of Appeal, Third Division (sitting in Santa Ana, California):

"Names and reputations take time to build, but are destroyed in an instant...The contract that was to bring fame to Anaheim will instead bring shame."

Regarding the proposed new name of the franchise, the brief employs a sports analogy (and a thinly veiled shot at the team): "Anaheim will be dumped from the name as abruptly as David Eckstein was shipped to St. Louis."

The City's brief continues: "With the clock ticking, and millions of taxpayer dollars at stake, the trial court erred in failing to bite the bullet on this claim... Anaheim was clearly bargaining for the name recognition given to locations associated with Major League Baseball teams."

"Defendant (Angels Baseball, L.P.) used its discretion to embarrass Anaheim and deny Anaheim the exposure for which it plainly bargained. This breaches Defendant's duty of good faith and fair dealing."

As discussed here previously, the City relies, in part, on the declaration of Antonio G. Tavares, former president of Disney Baseball Enterprises, who negotiated and agreed to the terms of the 1996 contract between Anaheim and the Angels. "The [Tavares] declaration further closes the already tight loop on the parties' actual intent: 'Never did we contemplate that the team name would include another geographic name in addition to Anaheim, as this would be inconsistent with the purpose of Section 11(f): to give Anaheim prominence and closely identify Anaheim with the team so that Anaheim would be publicized when the baseball team was publicized.'"

The City's attorney also opines that using the Angels' logic, the following names also would have be contractually permissible: "The Angels who are Embarrassed to be Associated with Anaheim" or "The Angels of the Disgusting City of Anaheim" or "The Angels Formerly Known as the Team Identified with Anaheim." In the end, the argument concludes that "we sense and know that the law does not permit such absurdities. Technical compliance with a contract has never trumped the reasonable expectation of the parties."

Although not argued in the appellate papers, I came across an interesting tidbit. The full name of Los Angeles was "El Pueblo de Nuestra Senora la Reina de los Angeles de Porciuncula". (HT: Stones Cry Out, "35 Facts You Were Perfectly Happy Not Knowing", February 25, 2005.)

"El Pueblo de Nuestra Senora la Reina de los Angeles de Porciuncula Angels of Anaheim". Has a nice ring, don't you think?