St. Louis Convention & Visitors Commission v. National Football League

In 1988 the City of St. Louis was in search of a football team, and to attract one, St. Louis built a football stadium. Issues related to control over the football-stadium lease deterred certain expansion teams from considering the city. At one point, St. Louis decided to recruit the Los Angeles Rams, which was interested in moving. St. Louis assigned the stadium lease to the St. Louis Convention & Visitors Commission (CVC) (plaintiff). Once CVC began negotiating with the Rams to move, CVC did not seek any other potential lease bids. Proposed team relocations were governed by Article 4.3 of the National Football League (NFL) (defendant) constitution, which required prior approval from three-fourths of team owners. Article 4.3 further provided factors that team owners should consider in evaluating the proposed relocation. The team owners initially disapproved the relocation, in part because the Rams would not agree on a relocation fee. After CVC confidentially agreed with the Rams to pay some amount for a relocation fee, the Rams and the NFL reentered negotiations. Ultimately, the Rams agreed to pay the NFL a relocation fee of $29 million, among other concessions, and the NFL approved the relocation. CVC agreed to pay $20 million of the relocation fee. The Rams began playing in St. Louis in 1995. That same year, CVC was unable to meet its financial obligations to the team. CVC sued the NFL alleging that the NFL’s relocation policy and procedures violated § 1 of the Sherman Act by creating an anti-relocation atmosphere, which discouraged interested teams from bidding on CVC’s lease. CVC asserted that the lack of bidders caused CVC to lease the stadium on less favorable terms than CVC otherwise would have. The district court conducted a four-week jury trial during which team owners, the Rams’ owner, and experts testified. The court ruled in the NFL’s favor on the ground that CVC presented insufficient evidence to establish an antitrust violation. CVC appealed.