Angels in the Courthouse: The Opinion.

As reported here (pretty close to first), the Angels won the latest inning in its legal contest with Anaheim.

1. The Recap.

In short, the Fourth District (Third Division) Court of Appeal refused to vacate the trial court's pretrial ruling in favor of the Angels. Earlier, the City had requested that the Orange County Superior Court block the team's name change to the Los Angeles Angels of Anaheim. However, the Superior Court judge ruled that the name change "technically complied" with the terms of the lease between Anaheim and the Angels, which required that the Anaheim be "included" in the name.

So, the municipality filed a petition for writ of mandate prior to the trial to overturn the trial court's ruling. The trial court accepted the petition (an unusual occurrence), and the matter was argued on March 28, 2005. (Here's my account.)

Justice Sills suggested at the hearing that the parties try to resolve their dispute before a mediator. The parties attempted mediation, but the matter did not settle. As a result, the matter returned to the appellate court to decide the writ petition within 90 days of the oral argument. That decision materialized last week. Read the unpublished opinion here.

2. The Majority Opinion.

Essentially, the court split 2-1. Two justices (Aronson and O'Leary) hung their hats on the notion that trial courts deciding preliminary injunctions like this are entitled to substantial deference, and that this judge did not "abuse [his] discretion" in ruling for the team. They wrote: "Our review is narrowly tailored to determining whether the court abused its discretion in denying the preliminary injunction. ... The trial court's decision...was supported by substantial evidence and was well within the bounds of reason." They continued: "[T]he name Los Angeles Angels of Anaheim 'technically' complies with the express Lease provisions. ... [I]f the parties intended to designate Anaheim as the exclusive geographic component of the team name, use of the word 'include' ... was not an effective means to convey that intent."

They were quick to note that the parties should not take this as the final word, appropriating sports metaphors, of course. "Because of our inquiry's narrow focus, however, our decision today does not declare any party the ultimate victor. Indeed, at trial, today's opinion places neither party ahead or behind in the count."

3. The Dissent.

Justice Sills agreed only with the result--i.e. not to overturn the trial court, but only because it was too late to do anything about it. In fact, Justice Sills questioned at oral argument whether the court could do anything as of that date--March 28, 2005. The situation did not improve with time. As the season marched on, it became apparent that the City's petition was doomed.

The following encapsulates Justice Sills' position on the merits: "One doesn’t need to attend law school to know that language requiring Anaheim be included as part of the 'name' of a major league baseball team necessarily precludes subordination of Anaheim to that of another city in the team’s name. Journalists know that, English teachers know that and Joe Sixpack knows that. The 'Brooklyn Dodgers of Los Angeles' would not be a permitted name if Los Angeles were the beneficiary of a similar clause. The language of this contract is susceptible to no other reasonable interpretation. Anaheim bargained for something more than being a mere hiccup after the words 'Los Angeles Angels.' When preceded by 'Los Angeles Angels,' the words 'of Anaheim' effectively drop from being included in the team name and become nothing more than an optional prepositional phrase. Only the sophistry of lawyers allows such a result."

Where do we go from here? The trial is set for November 7, 2005. Justice Sills stated: "It is extremely important that the trial in this case, now scheduled for the Fall of 2005, go forward."