Academic journal article Sport Marketing Quarterly

Let's Here It for the Home Team: Williams V. National Football League Upholds Geographic Ticket Sales Ban

Academic journal article Sport Marketing Quarterly

Let's Here It for the Home Team: Williams V. National Football League Upholds Geographic Ticket Sales Ban

Article excerpt


In March 2015, a marketing executive for the Atlanta Falcons was fired and the team was penalized by the National Football League (NFL) Commissioner's office for piping artificial crowd noise into the Georgia Dome during home games ("Falcons Fined," 2015). It is just the latest example of the lengths to which professional sports teams will go in seeking to gain a competitive advantage by creating a more hostile environment for visiting teams.

For more than a decade, some NFL teams have limited ticket sales for home playoff games to specific geographic areas (typically based on zip codes) in an effort to try and ensure that more home team fans can procure tickets ... and that fans of the opposing team cannot (Farrar, 2014; Mohl, 2007; Roberts, 2014). With these ticket sales restrictions in place, visiting fans can access tickets, but typically only by paying higher prices on the secondary market. The New York Giants initiated the practice of limiting the sale of tickets to certain geographical locations in advance of their 2001 Divisional Playoff game against the Philadelphia Eagles (Roberts, 2014). In 2006, the San Diego Chargers limited ticket sales to southern California for their Divisional Playoff game versus the New England Patriots and the Chicago Bears used the same tactic in limiting ticket sales to Illinois and northwest Indiana for their Divisional Playoff game against the Seattle Seahawks (Mohl, 2007; Farrar, 2014). In 2008, the Tampa Bay Buccaneers used the tactic against the New York Giants for their Divisional Wild Card game. Instituting a geographic ticket sales ban has not always guaranteed success on the field; although the Giants and Bears won their respective home playoff games, the Buccaneers and the Chargers both lost their home playoff games.

The tactic of limiting the sale of tickets to specific geographic areas was adopted by Major League Baseball (MLB) in 2012. The Washington Nationals, frustrated by the number of Philadelphia Phillies fans who routinely traveled to Washington, DC, for Nationals home games (Phillies fans even began referring to the Nationals' stadium as Citizen's Bank Park South), initiated a "Take Back the Park" program. The team limited advance ticket sales for games against the Phillies to Nationals' season ticket holders and fans who resided in Washington, DC, Virginia, and Maryland (Beck, 2012; Boswell, 2012; Ladson, 2012; Loeb, 2012; "Phillies," 2011; Tanier, 2012). At least one team in the National Basketball Association (NBA) has also taken notice. In 2014, the sale of tickets for all Oklahoma City Thunder home playoff games were restricted to residents of Oklahoma, Kansas, Arkansas, Missouri, and Nebraska based on credit card billing addresses (Brown, 2014; Rose, 2014). The tactic was extended, for the first time ever, to NFL League Championship Games in 2014. Both of the participants in Super Bowl XLVIII, the Seattle Seahawks and the Denver Broncos, limited ticket sales for their respective NFC and AFC Championship games to fans based on zip codes.

Ticket sales bans appear to be gaining in popularity (Blount, 2014). The legal issue raised is whether limiting the sale of tickets to certain geographic regions passes legal muster. In other words, should all fans have a legal right to purchase single-game tickets regardless of where they live? This question was recently decided, at least with regard to one jurisdiction, in the case of Williams v. National Football League, et al. (2014).

Facts and Case History

John Williams, a San Francisco 49ers fan, was blocked from purchasing a ticket from the Seahawks to the 2014 NFC Championship game in Seattle (Florio, 2014). As a Nevada resident, Williams filed suit against the Seahawks, the NFL, Ticketmaster, and the State of Washington, alleging injury based on a variety of legal claims (Complaint, 2014). Williams argued that limiting the sale of tickets to an NFL playoff game only to those individuals with credit card addresses from the states of Washington, Oregon, Montana, Idaho, Alaska, and Hawaii, or the Canadian provinces of British Columbia and Alberta, was unlawful (Complaint, 2014; "Fan sues," 2014). …

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