Missouri Court of Appeals, Eastern District / Apr 16, 2019
St. Louis Regional Convention and Sports Complex Authority, et al., Respondents, vs. National Football League, et al., and The Rams Football Company, LLC and E. Stanley Kroenke, Appellants.
The St. Louis Regional Convention and Sports Complex Authority, the City of St. Louis, and St. Louis County sued the Rams, the NFL, and its owners, including E. Stanley Kroenke, after the Rams relocated from St. Louis to Los Angeles in 2016. Plaintiffs alleged various claims, including breach of contract, based on their status as third-party beneficiaries of the NFL's relocation policy. The Rams and Kroenke moved to compel arbitration, arguing that 1995 agreements contained mandatory arbitration provisions. The trial court denied the motion to compel. The appellate court affirmed, holding that the 1995 contracts did not clearly and unmistakably delegate arbitrability to an arbitrator, as the relevant AAA rule did not exist at the time of contract formation, and that Plaintiffs' claims were independent of the 1995 agreements.