On October 6, 2020, the Central District of California issued two orders in litigation stemming from COVID-19 ticket refunds. The first order dismissed claims against Major League Baseball (“MLB”) and certain out-of-state MLB teams for lack of personal jurisdiction and claims against certain other teams for lack of standing. The second order granted the Oakland A’s' motion to compel arbitration and the San Francisco Giants’ motion to dismiss for failure to state a claim.
- In April 2020, eight individuals brought a putative class action against MLB and each of its 30 member teams, claiming they were entitled to refunds for tickets purchased for games that were postponed due to the COVID-19 pandemic. The plaintiffs asserted claims for violation of California’s consumer protection laws, conspiracy, and unjust enrichment. The defendants moved to dismiss.
- In response to the motion, the court divided the plaintiffs into three groups: (1) those who purchased tickets to games scheduled to be hosted by the San Francisco Giants or the Oakland A’s' (the “Bay Area Teams”); (2) plaintiffs who purchased tickets for games to be played at teams’ stadiums outside of California (the “Out-of-State Clubs”); and (3) plaintiffs who purchased tickets for games to be played in California involving teams other than the Bay Area Teams (the “Remaining Defendants”). It then issued two orders.
- The court’s first order addressed the Out-of-State Clubs and the Remaining Defendants
- The court held that it lacked personal jurisdiction over the Out-of-State Clubs and MLB, relying primarily on Senne v. Kansas City Royals Baseball Corp., 105 F. Supp. 3d 981 (N.D. Cal. 2015), in which the Northern District of California held that it could not exercise personal jurisdiction over an out-of-state baseball...
