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."
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."
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.
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.
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.
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.
Thanks to legal correspondant G. Michael Vicklund,
J.D. for contributing to this story.
Simply Baseball Notebook