LOS ANGELES (Legal Newsline) - The City of Oakland isn’t entitled to damages over the relocation of the Raiders football team to Las Vegas, a California appeals court ruled, upholding the dismissal of a lawsuit claiming the National Football League and its member teams violated an agreement to consider a dozen factors including the impact a team’s relocation would have on the local community.
The NFL approved the move to Las Vegas in 2017 after a bidding war between the two cities. Oakland then sued the team and the league, accusing them of violating a relocation policy the NFL had worked out over the years in consultation with various cities and the Conference of Mayors, which listed 12 factors for teams to consider including the level of fan loyalty, the adequacy of the stadium, team financial performance and whether the team has received public financing.
Oakland said NFL team owners “went through the motions” of considering the factors before voting to allow Raiders owner Mark Davis to move his team to Las Vegas. Nevada and Las Vegas offered $750 million toward a $1.9 billion stadium and Davis officially relocated the team in 2020. Oakland said the move increased the value of the Raiders by $1.6 billion, which it called unjust enrichment.
The city claimed it was a “third party beneficiary” of the league’s relocation policy agreements, which it said the NFL and its member teams violated by failing to negotiate in good faith or properly consider the 12 factors. The trial court dismissed the case, saying the relocation policy “does not contain a promise that defendants will consider anything” and the 12 factors were suggestions, not requirements. Even if the relocation policy was a binding contract, the court ruled, Oakland wasn’t a third-party beneficiary because the agreement specified it was to protect and benefit the teams.
California’s Second Appellate District, Division Seven, upheld the dismissal in a Sept. 15 decision. While the NFL developed its relocation policy in consultation with municipal officials, the appeals court said, the text of the agreement makes it clear it is intended to benefit team owners.
“Even if the Relocation Policy’s benefits to host cities such as Oakland could only be realized by giving host cities the right to enforce the Policy, such a result would not be consistent with the reasonable expectations of the parties,” the court said. “Simply put, the defendants did not agree to constrain their ability to approve a proposed relocation for any reason.”