Baltimore Football Club, Inc. v. Superior Court

In this case we consider the propriety of certifying a nationwide class action of National Football League ticket holders for claimed damages arising out of a players’ strike. Petitioners, the owners of the 28 teams in the National Football League, seek a peremptory writ of mandate directing the respondent superior court to vacate its decision certifying a class action against all of the petitioners on behalf of all season ticket holders of each team. The underlying action seeks damages based upon claims of unjust enrichment from the use of season ticket purchase money during a year in which games were cancelled due to the strike. We conclude that the requisite community of interest is lacking as to the multiple defendants and for that reason shall issue the writ.

Facts

This dispute arose as the result of the 1982-1983 players’ strike against the National Football League clubs. On December 9, 1982, real party in interest Rameo, Inc., filed a complaint naming as defendants each of the 28 National Football League teams. It was alleged that Rameo, Inc., had purchased a season ticket for the 1982-1983 football season from the San Francisco Forty-Niners, and that the season…