This matter is comprised of three consolidated lawsuits relating to the St. Louis Rams football team’s January 2016 decision to move the team to a new stadium in Inglewood, California. Those cases are captioned
McAllister v. The St. Louis Rams, No. 4:16-CV-172 (E.D. Mo.) (“McAllister”)
Envision, LLC, et al. v. The St. Louis Rams, LLC, No. 4:16-CV-00262 (E.D. Mo.) (“Envision”)
Arnold, et al. v. The St. Louis Rams, LLC, No. 4:16-cv-00297 (E.D. Mo.) (“Arnold”)
A fourth case that had also been consolidated into this matter, Pudlowski v. St. Louis Rams, LLC, 4:16-cv-189-SNLJ (E.D. Mo.), was remanded to state court on March 21, 2018.
The Rams’ home stadium had been located in St. Louis, Missouri since 1995. Football fans who wished to purchase season tickets were required to buy Personal Seat Licenses (“PSLs”) that entitled the PSL holder to buy one season ticket per year in a designated section of the stadium.
Upon the announcement that the Rams would move to California, lawsuits were filed by PSL holders and others against the Rams claiming damages arising from the Rams’ move. The Rams claim that all rights and obligations under the Rams and FANS Contracts expired when the team moved to California, and lawsuits were filed. Plaintiff McAllister alleged that the Rams terminated the PSLs thus triggering the Rams’ contractual duty to refund “deposits” that the Rams had received. Two other groups of plaintiffs --- led by Envision and Arnold --- sued under the theory that the Rams were still required to use “best efforts” to secure tickets to home games in California for PSL holders and that PSL holders still had the right to transfer their PSLs by sale or otherwise.
Early on, the parties filed motions to test the plaintiffs’ legal theories. The results depended entirely on which PSL Agreement --- the FANS Contract or the Rams Contract --- was at issue. The Court held that the “best efforts” obligations expired along with the FANS Contract upon the Rams’ move to California based on a clause unique to the FANS Contract: “The Rams terminated the FANS Agreement because it became invalid on the Rams’ move to California and now must ‘refund…deposits’” according to the contract. (#44 at 11.)
On the other hand, the Rams Contract contained no such clause, so it was not terminated upon the Rams’ move to California. The Rams Contract requires the Rams to use “Best Efforts to secure tickets for seats at games where the transferred home games are played.” (#44 at 8.)
The result was that the Arnold and Envision “ticket theory” applied to the Rams PSL Contract while the McAllister “refund theory” applied to the FANS PSL Contract.
The Court granted class certification to the plaintiffs on March 13, 2018. (#355.)
This Court certified a class of FANS PSL Holders and a class of Rams PSL Holders.
1. FANS Class and Subclass definition:
FANS Class. All persons or entities who, at the conclusion of the 2015 season, owned a PSL purchased from Fans, Inc. that was not later transferred or upgraded.
FANS MMPA Subclass. All natural persons who are members of the FANS Class and who never claimed the PSL expense as a tax deduction for business purposes.
McAllister was appointed as class representative for the FANS class, and his counsel was appointed class counsel for the FANS class.
2. Rams Class and Subclass
A) All persons or entities who:
1) purchased PSLs directly from the Rams; or
2) had any Rams or FANS PSL transferred to them; or
3 upgraded their PSL tier; and
B) purchased Rams season tickets through their PSLs for the 2015 season; or
C) did not purchase Rams season tickets for the 2015 season but did not receive a PSL cancellation notice from the Rams.
MMPA subclass: All natural persons who are members of the Rams Class who purchased PSLs primarily for personal, family, or household purposes and who never claimed the PSL expense as a tax deduction for business purposes.
The Court appointed the Arnold plaintiffs as class representatives. At the invitation of Arnold’s counsel, counsel for both Arnold and Envision was appointed as class counsel.
Chambers of U.S. District Judge Stephen N. Limbaugh, Jr.
555 Independence St.
Cape Girardeau, MO 63703
Judicial Assistant: Jessica Carter (573)331-8873
Settlement approval hearing on June 24, 2019 at 10:30