United States: What The League Giveth: St. Louis' Key Role In The History Of NFL relocation

If you have lived in St. Louis for 55 years or longer, you have enjoyed a front row seat to the history of NFL team relocation. Actually, considering the vitriolic opinions of Rams fans that have flown across local newspaper pages, web sites, radio stations and television networks over the last year, "enjoyed" may not be the best description. 

Indeed, it is an understatement to say St. Louisans have experienced a slightly fraught relationship with the NFL. They have witnessed a team arriving — at the NFL's behest. And they have witnessed a team leaving— with the NFL's blessing.

But setting aside the controversies and extreme fan reaction that accompanied these moves, it is fascinating to dive into the history of NFL relocation and revisit the considerable political, financial, and business machinations that gave professional football to St. Louis and, a half century later, took it away. 

St. Louis doubles up on Cardinals

The modern history of NFL team relocation may have started in 1960 when the Chicago Cardinals moved to St. Louis and became the St. Louis Football Cardinals1. The Football Cardinals were owned by the Charles W. Bidwill family and, in 1960, controlled by his widowed wife Violet Bidwill Wolfner. 

At the time, Chicago was home to two football teams, the Bears and the Cardinals. The NFL concluded that St. Louis could support an NFL team and that such a relocation would help the Chicago Bears and the NFL's future television plans. Additionally, St. Louis was planning on building a new stadium to replace its aging baseball stadium, Sportsman's Park, and this new stadium was part of the lure to bring a football team to the city. Progress in building the stadium, however, was very slow, and despite the 1960 promise, which was critical to the NFL and the Cardinals, as of 1964 the new stadium in St. Louis was still only a concept.

Meanwhile, Atlanta was also hatching plans for a new stadium and trying to attract a football team to play in it. As is often the case in negotiations, once the Football Cardinals expressed some interest in the Atlanta proposal, St. Louis swiftly fulfilled its promise of a new stadium. Busch Memorial Stadium was completed in 1966 in time for the NFL season. 

Busch Memorial was contoured primarily for baseball and was the centerpiece of a downtown redevelopment project under the auspices of the Civic Center Redevelopment Corporation (CCRC), a not-for-profit entity established to oversee and manage the downtown renovation. To fund the project, Anheuser Busch (AB), the baseball team's owner, kicked in $5 million dollars and the Football Cardinals agreed to forego any revenue from parking or concessions. With that, the perfectly circular 50,000 seat stadium project, which included nearby parking garages, a hotel, and other property, joined the St. Louis skyline, just west of the equally curvy St. Louis Arch, completed the prior year.

Trouble on the field

For the next 15 years, the baseball and football teams shared Busch Memorial Stadium, with each team enjoying some limited on-field success. In 1981, after a nasty court fight, AB acquired the CCRC. The deal gave them control over the stadium — and the ability to drop "Memorial" from its name — along with the lucrative parking and concession businesses. The deal relegated the Football Cardinals to a subordinate position; they were now a tenant in a privately owned stadium of another sports franchise.

Further complicating the issue was the growing size of NFL stadiums across the country. Despite the fact that the Football Cardinals averaged 47,000 people per game (90% of capacity at Busch Memorial), they were about 13,000 below the average NFL stadium capacity, which was only growing larger. Football Cardinals owner William V. "Bill" Bidwill, who became the sole owner in 1973, became very concerned about this growing gap, as well as the limited streams of revenue that his team could tap into. In 1984, he began publically discussing the need for a new stadium for his team.

After much discussion, St. Louis City Mayor Vincent C. Schoemehl and St. Louis County Executive Gene McNary held a joint press conference in in April 1985 to announce that the City and County would cooperate in their efforts to keep the Football Cardinals in St. Louis. Both Schoemehl and McNary acknowledged that a new stadium was necessary as Busch Stadium had become inadequate for NFL football. 

Phoenix rising 

Once again, progress on a new stadium moved slowly. Despite Schoemehl's pledge of cooperation, he vacillated between supporting, opposing and obstructing the building of any stadium for the Football Cardinals. McNary, on the other hand, remained steadfast in his desire to build a new home to retain the football team in the St. Louis area. McNary even secured land to build a stadium in St. Louis County for the Football Cardinals. Bill Bidwill was so impressed with the County's plan that he purchased approximately 125 acres of land adjacent to the county site and signed a letter of intent to play in a new dome stadium to be built in St. Louis County by private investors. 

Schoemehl, with the backing of certain downtown interests, in July 1987 filed a lawsuit against the Football Cardinals to force them to remain at Busch Stadium and also raised several environmental challenges about the county site and plan. As a result, McNary abandoned his plans for a multi-purpose dome stadium and replaced it with proposed plans for an outdoor county stadium. In exchange for the Mayor's support for the outdoor stadium, McNary agreed to support the expansion of the downtown convention center. The Football Cardinals and its financial consultants after studying McNary's new plan, concluded that an outdoor stadium under the terms now proposed was "unworkable" for the franchise.

Bill Bidwill then announced that the Cardinals would look for a permanent solution to its stadium challenges and in January 1988 filed "A Statement of Reasons" with Commissioner Pete Rozelle and the other member clubs to relocate the Football Cardinals to the Phoenix area. The Raiders' rocky transition during their initial move to Los Angeles from Oakland — and the resulting litigation — prompted the NFL to establish guidelines for moving a franchise. The Football Cardinals' application was the first such relocation application filed by a team2.  

In its application, the Cardinals set forth the struggles it had encountered in trying to build a new stadium more consistent with the size of its NFL team brethren. The Football Cardinals' application did not criticize its fans or negatively characterize the St. Louis market. Instead, it focused on the lack of any civic plan to address its needs and the potential of the Phoenix area as an NFL market. In March 1988, the NFL owners overwhelmingly approved the Cardinals relocation from St. Louis to the Phoenix area3

Attracting the L.A. Rams

Meanwhile in Southern California, the saga of the Rams in the Los Angeles area had gone on for almost a quarter of a century. L.A. Rams owner Carroll Rosenbloom had moved his team from the L.A. Coliseum to Orange County and a stadium in Anaheim. Part of this move was a real estate play and a chance to develop the areas surrounding the stadium. When Carroll Rosenbloom died in 1979, his wife, Georgia, inherited the team from him but was never able to get the real estate development off the ground. This inability and the fact that a team in Orange County did not have the same appeal as an L.A.-proper team dampened the Rams' long term prospects in Anaheim. The team began looking for alternative playing sites, but after encountering a limited appetite in Southern California for a new stadium, the team initiated a broader search in 1994 for place to move its operations. 

Back in St. Louis, there was a stadium-sized hole in the hearts and minds of St. Louisans after the departure of the Football Cardinals. The public began a real push to bring NFL football back to the city. Jerry Clinton, a prominent AB distributer, Fran Murray, a Philadelphia businessman, and Hall of Fame football player Walter Payton decided to pursue an expansion team for St. Louis. 

As part of the expansion pitch, Murray, Clinton and Payton developed plans for a new stadium and convinced St. Louis leaders that a dome stadium should be built as part of the expansion of the St. Louis Convention Center. Construction began before the NFL had chosen its expansion cities. Still, the Clinton-Murray-Payton group had some significant financial challenges. Even after recruiting Columbia, Mo., billionaire E. Stanley Kroenke to its cause, St. Louis was not chosen for expansion by the NFL, which instead opted for Charlotte, N.C., and Jacksonville, Florida. St. Louis was devastated by their omission — it was a blow not only to civic pride but to civic pocketbooks: The city now had an in-construction $300 million dollar stadium with no football tenant to occupy it.

At the negotiating table

The Rams' desire to move and St. Louis' need to find a tenant made the two parties perfect negotiating partners. A highly influential group of backers, under the auspices of FANS, Inc., formed the St. Louis side of the deal. It included U.S. Congressman Dick Gephardt, retired U.S. Sen. Thomas Eagleton, the city's mayor, the county executive, and several of the area's top business leaders.

The Rams, led by its President John Shaw, proved to be tough negotiators and agreed to a very favorable lease for the team with the St. Louis Convention and Visitors Commission ("CVC"), the future landlord of the about-to-be-completed domed stadium. In the Lease, the Rams agreed to pay the CVC $25,000 in rent per game, plus half of game day expenses. In return, the Rams would receive all of the ticket revenue from its games, 75% of the first $6 million in advertising revenue and 90% of the remainder, 100% of the profit from the concessions at Rams games and a portion of the concession profits from other events. St. Louis also agreed to a number of other obligations, including promises to pay $28 million to fulfill bond obligations owed by the Rams on the Anaheim Stadium and pay the team's moving costs, as well as agreeing to build a $9.9 million training facility. 

The Rams' Lease with St. Louis at that time became the gold standard and the envy of the rest of the NFL teams. Although the financial terms were lauded, the Lease also included a clause that the St. Louis stadium had to be maintained as to be in the top 25% of NFL stadiums at specific measuring dates using listed and specific components at the stadium. If St. Louis failed to meet these "First-Tier" standards, the Rams had the right to convert the Lease to a year-to-year lease and could pursue an alternate venue, either within or without the St. Louis area. 

The Lease was generally regarded as a windfall for the Rams, a fact CVC acknowledged when in 1997 it sued the NFL on antitrust grounds alleging that the NFL rules on franchise relocation were anti-competitive, putting them at a severe disadvantage in negotiating with the team and resulting in the inclusion of favorable team terms. The case was dismissed by U.S. District Court Judge Jean Hamilton and the Lease remained in effect4

'First-Tier' expectations

The Rams played in the Dome5  for the next 20 years, snagging a Super Bowl victory in 1999 (and falling just short of another in 2001, much to the chagrin of St. Louis fans, who have maintained a smoldering disdain for Tom Brady ever since). 

The measuring dates for determining "First-Tier" status were at 10 and 20 years into the 30-year term; the first date was reached in 2005. As was provided for in the Lease, the Rams and CVC began meeting and discussing what needed to be done in order for the CVC to meet the first-tier status. Interestingly, and perhaps unfortunately for St. Louis, there were at that point 20-plus new or substantially renovated NFL stadiums that would be relevant to the determination. However, after much discussion, the Rams agreed with the CVC to amend the Lease and forgo the 2005 measuring date in exchange for $30 million in Rams-directed upgrades to the Dome, which included new video boards and revenue-generating hospitality areas. This amendment also set forth a specific procedure to address the next first-tier measuring date. The procedure, including arbitration, allowed for an exchange of each side's ideas of what would be needed at the Dome to satisfy the first-tier requirement, and a time frame for a decision6.  

After Rams owner Georgia Frontiere passed away, her children shortly thereafter sold the team to Stan Kroenke7.  He and the CVC went to arbitration in 2012 to determine whose vision of "first tier" the arbitrators would accept. The Rams presented a $700 million renovation. The CVC countered with $120 million in upgrades. The arbitrators came down on the side of the Rams. The CVC and the Regional Sports Authority sponsors — the City of St. Louis, St. Louis County, and the State of Missouri — unanimously agreed that they could not finance the Rams' proposal, which was required without any additional time added to the Lease, and so informed the Rams. Consequently, the Rams became free to negotiate or find another place to play, and after the 2014 season were free to exercise their option to turn the Lease into a year-to year term lease. The Rams in January 2015 informed the CVC of that intention.

It soon became evident that Kroenke had great interest in the Los Angeles area as the place to relocate his team. He purchased the Hollywood Park racetrack in Inglewood and after first denying that he did so for the Rams, eventually unveiled plans to build a stadium along with substantial real estate development plans. Missouri Governor Jay Nixon responded to Kroenke's California intentions by appointing a two-person task force to develop a plan to keep the Rams in St. Louis. 

The task force developed a plan for a $1 billion open air stadium on the Mississippi River, which included substantial public dollars, and submitted their plans to NFL ownership. Kroenke showed no interest in the St. Louis plan and on January 6, 2016, submitted an application, as did the San Diego Chargers and Oakland Raiders, to relocate the team to Los Angeles. Kroenke's application and the accompanying Statement of Reasons, unlike the Cardinals' application in 1988, were highly critical of the St. Louis fan support and the region's long-term ability to support an NFL franchise. The NFL found that the Rams had satisfied the League's relocation guidelines, as did the Chargers and the Raiders. The League, however, made it clear that all three teams would not be allowed to relocate to LA and by a vote of 30-2 gave the Rams the right to develop its Inglewood site and relocate back to Los Angeles starting in 2016. 

The Rams held a press conference on January 14, 2016, trumpeting their excitement to begin a new chapter in Los Angeles. Banners bearing the 1999 "World Champions" title were removed from the Edward Jones Dome and plans to move the Rams operation to Los Angeles began to formulate. St. Louis reacted angrily to the news, expressing dissatisfaction with the NFL and its process. A lawsuit alleging deceptive advertising was filed against the Rams and its owner as well as a challenge to the St. Louis PSL agreements that potential ticket buyers signed allowing them to buy season tickets. 


As former St. Louis Football Cardinals and Hall of Fame Player Dan Dierdorf said in an interview after the relocation approval, St. Louis will survive without the NFL. It did so for the seven years after the Football Cardinals moved and it will do so now. St. Louis provided a plan that included between $350 and $500 million in public money only 20 years after constructing a $264 million stadium. The NFL revised its application process twice since the Raiders first move to Los Angeles but acknowledged that the rules were subjective guidelines to be applied by the 32 NFL owners.

San Diego and Oakland remain in limbo. The Chargers now have less than one year to make a deal with Kroenke to share the Inglewood Stadium, and are feverishly working to remain in San Diego. If the Chargers choose not to go to L.A., the Raiders can decide to move there, although the Raiders have strongly stated that their preference is now to relocate to Las Vegas. 

The NFL returns to a lucrative Los Angeles market and gets a planned state-of -the art stadium, including NFL-themed developments and attractions. During the 2016 preseason and early season games, the Rams have drawn very well in its temporary L.A. Coliseum home. St. Louis spent several million dollars in its efforts to keep the Rams but is back to having a stadium with no football tenant. On September 21, 2016, District Court Judge Stephen Limbaugh found that certain PSL agreement provided some rights to the PSL owners to tickets or refunds despite the relocation.8 The Rams have asked the court to reconsider its decision.

As you can tell, there have been fits and twists to St. Louis' odyssey with professional football. During the last 50-plus years, it enjoyed both the the "Cardiac Cardinals" of the 1970s and the "Greatest Show on Turf" of 1999-2004. It hosted a Super Bowl Champion team and enjoyed a large parade celebrating its first and perhaps only NFL Championship. It enjoyed great Hall of Fame players Larry Wilson, Dierdorf, Jackie Smith, Roger Wehrli, Marshall Faulk, Aeneas Williams, and Orlando Pace, as well as fan favorites Jim Hart, Roy Green, Isaac Bruce, Kurt Warner, and Torry Holt. 

It has been a fun and interesting journey and who knows whether the curtain has come down on the final act of NFL football in St. Louis. Only time will tell.


1 The team was specifically called the "Football Cardinals" because, as everyone knows, St. Louis was home to a baseball team called the St. Louis Cardinals. The NFL's entry into the city spurred the media to start referring to the occupants of Sportsman's Park as the "Baseball Cardinals."

2 Section 4.3 of the NFL Constitution required three-fourths of the then existing NFL franchises to vote for a team to relocate. After the Oakland Raiders moved from Oakland to Los Angeles in 1980 the NFL attempted to enforce Section 4.3. The NFL, as a result of this case, promulgated guidelines for teams to move and a procedure for doing so. 

3 The author served as outside counsel to the Football Cardinals and helped write the application to relocate.

4 See St. Louis Convention and Visitors Commission v. National Football League. United States Court of Appeals, Eight Circuit (1998), which affirmed the District Court ruling. 

5 The dome stadium was first named the TWA Dome. After the airline's bankruptcy, the naming rights were resold in 2001 to financial consulting firm Edward Jones and the facility was renamed the Edward Jones Dome. 

6 The author also participated in the discussions regarding the first tier process.

7 Stan Kroenke became a minority partner of the Rams in 1995 and helped moved the team from Los Angeles. He originally held a 30% interest which he increased to 40%. He had the right of first refusal to buy the team, and after Shah Khan made an offer to Ms. Frontiere's children, Kroenke exercised his right and became the majority owner.

8 McAllister v. St. Louis, No.4: 16-CV-172 SNLJ (E.D.MO.)

This article originally appeared in Professional Sports and the Law, a Hackney Publication

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.