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Indianapolis Colts v. Mayor and City Council of Baltimore

United States Court of Appeals for the Seventh Circuit
741 F.2d 954 (1984)


In 1984, the Indianapolis Colts (Colts) (plaintiff) were contemplating a move from Baltimore to Indianapolis. The Maryland Senate enacted legislation allowing the City of Baltimore to acquire the Colts by eminent domain. Pursuant to such legislation, the Mayor and City Council of Baltimore (collectively Baltimore) (defendants) filed a condemnation action against the Colts in a Maryland state court. Having learned about the lawsuit a few days before its filing, the Colts’ owner, Robert Irsay, moved the team to Indianapolis in the middle of the night and signed a lease for the Hoosier Dome with the Capital Improvement Board of Managers of Marion County, Indiana (CIB) (defendant). The CIB lease automatically terminated at the Colts’ discretion if the franchise was acquired by eminent domain. Another lease provision gave CIB a right to find a purchaser for the Colts if Irsay decided to sell. After the Colts arrived in Indianapolis, they filed an interpleader action, pursuant to 28 U.S.C. § 1335, in a federal district court in Indiana, alleging conflicting claims between CIB and Baltimore. The district court enjoined Baltimore from pursuing its condemnation action and proceeding with an action against the NFL designed to keep the Colts in Baltimore. Baltimore appealed the orders of the district court.

Rule of Law


Holding and Reasoning (Bauer, J.)

Dissent (Coffey, J.)

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