Fans Win Refund or New Tickets in Rams Relocation Class Action

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A court ruling issued Wednesday says the Rams must provide personal seat license holders in St. Louis the right to buy season tickets in Los Angeles, or must provide them a refund.

U.S. District Judge Stephen N. Limbaugh Jr. ruled that the Rams must grant season tickets to fans who bought personal seat licenses while the NFL team was in St. Louis, and those PSLs are still valid despite the team’s move to Los Angeles.

The judge also ordered the Rams to refund deposits for fans who bought PSLs, despite being unable to determine an amount for those deposits.

Three different groups sued the Rams on behalf of more than 45,000 people who bought PSLs before the team relocated back to Los Angeles in January.

Some who sued alleged the Rams essentially terminated their contracts with the PSL holders when the team moved, and owe them a refund as a result.

Two of the parties, plaintiffs Envision LLC and Richard Arnold, claim that their PSLs were still valid despite the Rams’ relocation and that they had the right to purchase season tickets in Los Angeles.

Some plaintiffs reportedly paid as much as $1,000 for the licenses, which grant the right to buy season tickets.

The Rams argued that these contracts were voided by the team’s move to Los Angeles.

The third Rams Season Ticket License class action lawsuit brought by disgruntled fan, plaintiff Ronald McAllister, argued that the Rams in effect terminated their contracts with PSL holders when they relocated to Los Angeles, and PSL holders therefore were entitled to refunds on their deposits, based on the language in the PSL contract.

In July, the three lawsuits were consolidated into one case.

Judge Limbaugh based his ruling on the fact that two different kinds of PSL contracts were issued.

Some were sold by the Rams ticketing agent, FANS Inc., and the others were sold directly by the Rams.

Both the PSL agreements note, in the event the Rams play at a venue other than their regular St. Louis stadium, the Rams must “use its best efforts” to provide seats for PSL holders.

Judge Limbaugh concluded that the latter provision “appears to trump all other provisions, including the ‘best efforts’ provision.”

However, the Rams must “use its best efforts” to provide season tickets for people who bought PSLs directly from the team, because that particular contract never states the PSL agreement is terminated by relocation.

Even though both the FANS and Rams contracts say a PSL holder cannot sue for damages over PSLs, the Rams failed to present that as an argument or even mention it in court, according to the ruling.

In the McAllister case, the judge noted out that the FANS contract says the Rams have the right to terminate the PSL contract for any reason and refund “part or all” of the PSL holder’s deposit.

“[B]y the [FANS] agreement’s own terms, the right to terminate and a refund of deposits go hand-in-hand. Therefore, the Rams must refund deposits under the FANS agreement,” the judge stated.

The matter of what deposit amount will be refunded must be decided at a later date since it cannot be determined by the contract, and is a matter of damages, the judge also said.

Arnold is represented by Fernando Bermudez and Martin Green of the Law Offices of Martin Green PC.

Envision is represented by David R. Bohm of Danna McKitrick PC.

McAllister is represented by Richard S. Cornfeld of the Law Office of Richard S. Cornfeld, Anthony S. Bruning, Anthony S. Bruning Jr. and Ryan L. Bruning of the Bruning Law Firm LLC and Mark Goldberg, Thomas P. Rosenfeld and Kevin P. Green of Goldenberg Heller & Antognoli PC.

The Consolidated St. Louis Rams Season Ticket License Class Action Lawsuit is McAllister v. The St. Louis Rams LLC, Case No. 4:16-cv-00172, in the U.S. District Court for the Eastern District of Missouri.

UPDATE: On March 13, 2018, a Missouri federal judge granted Class certification to two Classes of former Rams season ticket holders who were affected by the team’s move from St. Louis to Los Angeles.

UPDATE 2: On April 12, 2018, a federal judge denied a motion by the NFL Rams last week, attempting to delay a class action lawsuit over season ticket licensing. In addition, the judge ordered the organization to produce pricing data related to the team’s move from St. Louis to Los Angeles.

UPDATE 3: On Dec. 5, 2018, ticketholders managed to secure a $24 million class action settlement over allegations that the NFL failed to properly repay purchasers after moving its Rams from St. Louis to Los Angeles in 2015.

UPDATE 4: February 2019, the St. Louis Rams personal seat license class action settlement is now open. Click here to file a claim.