A Look at the Minnesota Appellate Court Ruling that You Don't Need a Lawyer to Understand.

On January 22, in a suprising turn of events, the Minnesota State Appellate Court upheld a temporary injunction that states the Minnesota Twins must play in the Metrodome in 2002. The injunction, issued by District Court Judge Harry Crump in November, was viewed by many at the time as a home town decision designed to delay the inevitable elimination of the Twins. Upon closer examination by Chief Judge Toussaint and Judges Schumacher and Klaphake, however, the decision was found to be sound in it's merit.

What is a Temporary Injunction?

A temporary injunction preserves the status quo of the contract/relationship until the case can be brought to trial. In other words, a temporary injunction keeps everything the same until all of the legal issues and/or ramifications have been sorted out. It is called "temporary" because it only remains in place until the resolution of the case. Once all the legal issues have been sorted out, than if necessary, a permanent injunction could be issued. This temporary injunction will cease to exist upon resolution of the case.

A district court judge has wide discretion in deciding whether or not to issue a temporary injunction. A district court must consider the following five factors when deciding whether or not to issue a temporary injunction: (1) the nature and background of the relationship between the parties, (2) balancing the harm to the plaintiff if the injunction is denied versus the harm to the defendant if the injunction is granted. (irreparable harm standard), (3) likelihood that one party or the other will prevail on the merits, (4) consideration of public policy expressed in enabling statute, and (5) administrative burdens involved in judicial supervision and enforcement.

More Than Simply Breaking a Lease

In many cases it is not a problem for a lease to be broken in a tenant-landlord relationship with proper monetary compensation. But, according to the court's findings the Twins and the Metropolitan Sports Facilities Commission (MSFC), which runs the Metrodome, do not have a typical tenant-landlord relationship. The Twins do not pay rent to the MSFC for use of the Metrodome for games or year round office and locker room space. The MSFC, however does receive around $500,000 annually by getting a cut of the ticket sales, concessions, and advertising revenues. Thus, according to the courts, the Twins "provide the state, citizens, and fans with substantial non-monetary benefits."

According to the court, "the (MSFC), the state, citizens, and fans would suffer irreparable harm if the Twins failed to play their 2002 home games at the Metrodome. The court (1) cited the role of baseball as a tradition and national pastime, the history of the Twins in Minnesota for some 40 years, including two World Series championships, the role of the Twins legends who have bettered the community by their volunteer work with children, and the availability of the Twins games as affordable family entertainment; (2) noted that private buildings has been condemned to build the Metrodome; (3) found that the welfare, recreation, prestige, prosperity, trade, and commerce of the people of the community are at stake; and (4) ruled that the vital public trust outweighs any private trust."

What that basically means that is the most valuable part of the Twins agreement with the MSFC is not money, but the promise to play baseball in the Metrodome. Pro sports is more than just a business, it provides a source of community pride and identification that cannot be measured by economics alone. The court is simply acknowledging that fact. The Metrdome was not built to make money, but instead "the stated purpose for building and operating the stadium was to attract major league sports franchises to play at the stadium for the enjoyment of the fans."

Another lesser known fact is that it was the Twins option to exercise the lease for the 2002 season, which they did in September. In 1998 the Twins signed a fixed term lease that expired after the 2000 season, but included a series of 3 one year extensions that could be used at the club's discretion. In September 2001 the Twins exercised that option. So, basically the team wants to go back on a promise that it made just over a month before the contraction proposal was made public.

According to the court the lease agreement was made between the Twins and the MSFC and that major league baseball cannot interfere with it. The court stated, "Although the relationship between the commission and MLB is not a contractual one, the Twins are a member of MLB. Accordingly, the injunction that the district court issued temporarily maintains the statue quo by requiring the Twins to play their 2002 home games at the Metrodome and by enjoining (restricting) MLB from interfering with the commissions contractual relationship with the Twins."

In an ironic twist the court used a statement by Bug Selig in a 1993 antitrust hearing before congress to support its argument. Selig stated that MLB should "vigilantly enforce strong policies prohibiting clubs from abandoning local communities which have supported," Selig went onto state that franchise relocation should be prohibited "except in the most dire circumstances where the local community has, over the a sustained period, demonstrated that it cannot or will not support the franchise." How contraction fits into the previous statements is anyone's guess.

The Twins and MLB claim that they are damaged by the injunction because the Twins lost $4 million last season and could lose as much this year. The court responded that the Twins have played in Minnesota for 41 years and exercised their option to play one more only months ago. In addition the Twins have to submit any evidence documenting their alleged loses.

The court went on to point out that this is merely a temporary injunction and not a permanent decision and that even though the plaintiff "may have serious obstacles to overcome before establishing its' right to what in effect amounts to specific performance of the franchise agreement."

The Court's Decision

In the end the court decided to uphold the injunction because it is supporting the status quo until a trial on merit. Thus, the main issue here is not to decide which side is right or wrong, but instead to determine if the District Court abused it's discretion. For all of the reasons stated above, it was determined that it did not. The injunction is upheld.

While this is clearly a victory for Twins fans, it does not guarantee the Twins will play in 2002. MLB is planning to appeal the case to the Minnesota Supreme Court and ask for a quick hearing because the clock is clearly ticking. The High Court has indicated it will hear the case, but a fast proceeding is far from a guarantee. If the cases proceeds to a trial, it will be heard on the merits. The lawyers for both sides will sort out the legal issues and one side will eventually win. However, this current action cannot keep the Twins in the Metrodome any longer than the 2002 season.

There is also the issue of the Collective Bargaining Agreement, or lack of, between the owners and players. Publicly both sides claim there will be no labor stoppage, but history says it is a possible. If a work stoppage occurs, the timetable for contraction could be considerably altered. Twins fans should enjoy this significant victory, but also take note that the 2002 season is not quite yet a reality and their future beyond that remains in doubt.

-David Zingler

Thanks to legal correspondant G. Michael Vicklund, J.D. for contributing to this story.