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Chapter 6 The Field-of-Dreams Approach: Baltimore and Indianapolis This is America and industries can move. But the difference is that Baltimore made an honest effort to keep the Colts. I gave Oakland the best operation in football and it wouldn't even give me $11 million in stadium improvements. The league will use this to say, "we told you so," but they could have stopped it if they wanted to. - Al Davis following the relocation of the Baltimore Colts to Indianapolis1 We felt we met every reasonable demand he made, but the demands kept changing. -Former Maryland Governor Harry Hughes 01) Colts owner Robert Irsay following the relocation of the Baltimore Colts to Indianapolis 2 There are two events in the history of Baltimore that are significant to this discussion of the sports franchise game. The first is the departure of the Baltimore Colts to Indianapolis in 1984, and the second is the construction of Oriole Park at Camden Yards for the 1992 Major League Baseball season. The city of Baltimore suffered due to the initial success of the Raiders in court against the City of Oakland and the NFL. Precedent did not support forcing a team to stay in its present location. Further, the zealous pursuit of Indianapolis for acknowledgment as '~merica's sports capital" did not help Baltimore either.3 The civic leaders ofIndianapolis, realizing that there were no nearby lakes, mountains, or sandy beaches, chose sport as the resource to serve as a tourist attraction and an imageimproving vehicle to spur development.4 This conscious effort began with the formation of the Indiana Sports Corporation, followed by increased investment in amateur sports.5 A survey conducted in the 1970s did not find that Indianapolis had a negative image, just that it had no The Field-of-Dreams Approach: Baltimore and Indianapolis 47 image at all.6 The success of the Raiders in court essentially neutralized a seemingly rigid rule from Seals barring unilateral franchise relocations. Some commentators referred to the Raiders' court decision as creating an atmosphere of free agency among franchises.' Colts owner Robert Irsay had been maneuvering to move the franchise from Baltimore to a new city for some time. Irsay had voiced the usual complaints, primarily regarding the need for stadium improvements. He reportedly was negotiating with Baltimore, Memphis, Phoenix, Jacksonville , and Indianapolis for several weeks before he made his move.8 But Irsay had not received league approval to move. Irsay appeared to be betting that the monetaryjudgment against the league of $49 million in Raiders tied the hands of the NFL. The question Irsay obviously asked himself was whether the league would risk another multimillion dollar judgment by attempting to bar a move by Baltimore. Irsay's view was "apparently not" - but with some degree of caution. On March 29, 1984, fifteen Mayflower moving vans loaded with all of the Colts' equipment rolled from Baltimore to Indianapolis.9 Press reports mention snowy, foggy weather conditions that appeared during a time of year when it rarely snowed in Baltimore. In response to the relocation , the league took no legal action.lO As the late columnist Pete Axthelm phrased the NFL's reaction to the flight, "It [the NFL] had no stomach for a fight with an owner who wanted to sneak out of town." 11 In retrospect, as legal scholars have analyzed the move, this was probably a relocation scenario that the league could have been successful in stopping without suffering antitrust damages. A key to the Raiders decision was the competition that their move to Los Angeles provided to the metropolitan Los Angeles-based Rams, not just in terms of on-the-field rivalry but in economic rivalry for fans in the metropolitan Los Angeles area.12 By not allowing this competition to occur, the NFL was acting anticompetitively. In contrast, when the Colts sneaked into Indianapolis , there was no neighboring franchise, and so the same anticompetition argument could not have been made against the NFL. The best explanation of why the NFL did not challenge the Colts in court is that the league was nervous and the legal dust from their losing encounter with the Raiders had not settled sufficiently. Indianapolis had made an offer that Baltimore, in the eyes of Irsay, did not seem willing to match. The Colts were playing in an old and outdated stadium when Irsay purchased the team in 1972 from Carroll Rosenbloom . Rosenbloom was not endeared to Baltimore's Memorial Stadium, and that...

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