ST. LOUIS – The U.S. District Court Eastern District of Missouri has ruled in favor of the St. Louis Rams in a lawsuit brought by a fan who purchased a Personal Seat License.
U.S. District Judge Stephen N. Limbaugh Jr. wrote the court's March 13 order, which denied plaintiff Ronald McAllister's motion for summary judgment.
McAllister alleged that he should get a refund because the Rams terminated the Personal Seat License contract when the team relocated the franchise to California in 2016.
“The St. Louis Rams required football fans who wished to purchase season tickets 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,” the order said.
Some fans purchased the Personal Seat Licenses directly from the team, while others like McAllister purchased from a third-party entity known as FANS Inc., which sold the tickets from 1995-1996, according to the order.
According to the FANS PSL agreement cited by the court, “the FANS PSL agreement terminated when the Rams no longer played football in St. Louis because the agreement states 'Licensee acknowledges that this agreement remains valid only as long as NFL Football is played at the Stadium by the Rams, up to a maximum of thirty (30) years.'”
McAllister said the Rams have terminated the PSL, therefore it has triggered the part of the contract that allows refunds.
According to the FANS contract, cited by the court, “The Rams terminated the FANS agreement because it became invalid on the Rams’ move to California and now must ‘refund…deposits.’”
The court also noted the Rams PSL agreement that requires the Rams to use “best efforts to secure tickets for seats at games where the transferred home games are played.”
“The court thus granted judgment on the pleadings to McAllister as to the FANS contract,” the order said. “The Rams moved to reconsider because, implicit in the court’s holding was that the Rams were liable under the FANS PSL agreement.”
According to the court, the Rams’ contract also says “the Rams were 'not parties' to the FANS agreement.”
McAllister said the Rams are liable for the FANS PSL agreement because “FANS Inc. was acting as the Rams’ legal agent and the Rams team was successor-at-interest to the FANS PSL agreement after FANS Inc. dissolved in 1998.”
The Rams argued against McAllister, saying FANS Inc. was only an agent for the Regional Convention and Visitors Commission.
Although McAllister said the Rams gave FANS Inc. the right to alter between the Rams and third parties, the court didn’t agree.
“FANS PSLs specifically provided that 'the Rams are not a party to this agreement' and further provided that the FANS licensees would have no rights against the Rams under the PSLs,” the court said.
Because the Rams continued to sell season tickets to FANS PSL holders, McAllister said the Rams continued to “administer” the FANS PSL agreement, therefore making them parties to the agreement, according to the order.
“Plaintiff again relies on agency law to argue that the Rams were a party to every FANS PSL sold by FANS Inc. because the Rams and FANS Inc. were in a principal/agent relationship,” the order said. “The court has already determined that it cannot hold as a matter of law that the Rams and FANS Inc. were in a principal/agent relationship. The plaintiff’s successor liability argument also fails.”