L.A. Angels of Anaheim Win Name Change Suit

A Santa Ana jury has ruled, inexplicably, that changing the team name from Anaheim Angels to Los Angeles Angels of Annaheim did not breach a contract requiring the team to be named after the city of Anaheim.

A jury ruled Thursday that the Angels did not breach a contract with the city of Anaheim when the baseball team changed its name.

Jurors rejected the city of Anaheim’s argument that the baseball team violated a stadium lease and cost the city where it plays at least $100 million in revenue by changing the name last year from Anaheim Angels to the Los Angeles Angels of Anaheim. The jury, which deliberated for a little more than four hours, also found the team did not violate a state law requiring good faith and fair dealing.

“I was trying to create something positive and more inclusive … which we believed was our legal right to do,” Angels owner Arte Moreno said. “Long term, we’re going to have a healthier franchise that can compete.”

I would have thought this one a slam dunk for the city of Anaheim. Every other franchise in professional sports is named in the same way: City/state name Team name. Clearly, the city had reasonable expectation, therefore, that the team would call itself the Anaheim Angels.

Further, while Anaheim remains appended to the name, the team is generally referred to as the Los Angeles Angels or L.A. Angels in all press reports or on sports tickers. There can be no doubt that this considerably diminishes to value received in exchange for the considerations offered by the city of Anaheim in the lease agreement.

Corrections from English to Californian made in spelling of city names.

FILED UNDER: Law and the Courts, Sports,
James Joyner
About James Joyner
James Joyner is Professor and Department Head of Security Studies at Marine Corps University's Command and Staff College and a nonresident senior fellow at the Scowcroft Center for Strategy and Security at the Atlantic Council. He's a former Army officer and Desert Storm vet. Views expressed here are his own. Follow James on Twitter @DrJJoyner.


  1. Russ says:

    Uh… one “n” in “Anaheim.”

  2. Patrick McGuire says:

    The team was right, they need to be more inclusive. They should be the “Los Angeles Angels of Anaheim California United States of America North America Western Hemisphere Earth” team.

  3. McGehee says:

    When are the Heavenly-Americans going to rise up and object to the demeaning use of their name and image for a baseball team mascot?

  4. the Pirate says:

    In a bit of irony, there is actually another team that doesn’t follow the City/state name Team name format: Mighty Ducks of Anaheim. (Although they are dropping the Mighty next season).

  5. ICallMasICM says:

    Wasn’t there a clause that said the name must make some kind of sense?

  6. LJD says:

    As a NH resident, I would have a hard time supporting the Boston Patriots of Foxboro.

  7. G A PHILLIPS says:

    They should be called “The Snivelling Little Demon Lovers of california” or “The Great Blue Hells fallen Angels” if they realy want to be P.C., and or inclusive. Oh, and good point Mcgehee. Infidels, Off with their heads!

  8. Gawaine says:

    Yeah, like the Lanham Maryland Redskins, or the New Jersey Giants, they should have been forced to use the real name of the tiny little place where they play instead of the honking big metropolis next door. It’s obvious, isn’t it?

  9. Steve Verdon says:

    I think you mean Santa Ana as well.

  10. James Joyner says:

    Gawaine: If the Redskins had signed a contract with Lanham to use their name in order to get a better deal on the stadium, then yes. The Angels have changed names every few seasons; it’s not like they have an established brand identity.

  11. floyd says:

    just shows that going to court doesn’t guarantee justice or common sense.the namers entered the agreement with the intent of finding a way around it,obvious dishonesty, but i guess legal.

  12. ICallMasICM says:

    They were the LA Angels from 61-64 when they played in LA

    They moved to Anaheim for the 1965 season and were the California Angels from 1965 – 1996. They changed their name to Anaheim in 1997 and were the Anaheim Angels from 1997 – 2004

  13. cf says:

    “Every other franchise in professional sports is named in the same way: City/state name”

    I know it’s a long time, but what about the ABA team “Spirit of St Louis”?