City of Oakland v. The Oakland Raiders
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The City of Oakland filed a lawsuit against the National Football League (the League or the NFL) and its 32 member clubs (collectively, Defendants) after one member club, the Raiders, relocated from Oakland to Las Vegas. The City alleged Defendants did not comply with the process for approving club relocations set forth in the NFL Constitution and related documents. The City asserted causes of action for breach of contract as a third-party beneficiary, breach of the implied covenant of good faith and fair dealing, and unjust enrichment. The trial court sustained Defendants’ demurrer to all three causes of action without leave to amend and entered judgment for Defendants.
The City argues the trial court erred in ruling it was not a third-party beneficiary of the NFL Constitution and related documents and therefore did not have standing to enforce those documents. The City also argues the court applied an incorrect legal standard in ruling on the demurrer to its cause of action for unjust enrichment.
The Second Appellate District affirmed. The court concluded that, because the City did not and cannot allege it is a third-party beneficiary of the alleged contracts, its causes of action for breach of contract and breach of the implied covenant of good faith and fair dealing fail. The court further concluded that the City has not and cannot allege facts sufficient to state a cause of action based on a theory of unjust enrichment.
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