SAINT LOUIS UNIVERSITY SCHOOL OF LAW
2006] THE MYTH & MYSTERY OF PERSONAL SEAT LICENSES AND SEASON TICKETS 243
packages generally give the purchaser rights to purchase tickets for the same
seat during highly sought after games.
8
For instance, most professional sports
fans that purchase season ticket packages enjoy the extraordinary right to
purchase tickets to post-season games, as well as All-Star Games played in the
stadium.
9
Additionally, they have the right to purchase individual and group
tickets to regular season games prior to their availability to the general
public.
10
The prices of such packages vary widely between stadiums and
according to seat locations.
11
In recent years, sports franchises have conditioned the purchase of season
tickets, especially for premium seating, on the fan’s purchase of a personal, or
private, seat license (PSL).
12
The rights conveyed by the PSL vary among
different franchises.
13
However, the seat license typically gives the purchaser a
right to buy season tickets in a premium seat location in the future.
14
Often,
these licenses also give the purchaser the right of first refusal for post-season
tickets and the right to transfer the PSL.
15
The term of the PSL also varies
from franchise to franchise.
16
In some cases, the PSL has an indefinite term
and will only terminate if the license holder violates the license agreement,
most notably by choosing to not purchase tickets for a season.
17
However, in
other cases, the seat licenses are valid for a term of years.
18
Like season
8. See St. Louis Cardinals 2006 Season Ticket Overview, http://stlouis.cardinals.mlb.com/
NASApp/mlb/stl/ticketing/season_overview.jsp (last visited Nov. 12, 2006).
9. Id.; S
T. LOUIS RAMS 2006 SEASON TICKET GUIDE, Ticket Policies & Information (St.
Louis Rams, St. Louis, MO 2006), available at http://www.stlouisrams.com/Tickets/
seasonticketguide; San Diego Padres 2006 Season Tickets (on file with The Saint Louis
University Law Journal).
10. New York Yankees Ticket Licensees, http://newyork.yankees.mlb.com/NASApp/mlb/
nyy/ticketing/sth_faq.jsp (last visited Nov. 12, 2006); Letter from Michael Hall, Director, Group
Ticket Sales, St. Louis Cardinals LLC to Season Ticket Holders (Dec. 21, 2005) (on file with
author).
11. Levengood, supra note 7, at 414.
12. Id. Often, the requirement that premium seat holders purchase PSLs occurs when the
franchise relocates or constructs a new stadium. See Doug Moore, Deal Makes Cards Owners of
Stadium: Team Will Contribute Extra Money for New Ballpark, S
T. LOUIS POST-DISPATCH, Dec.
24, 2003, at A11; Sam Walker, Craving Cash, Teams Ask Ticket Holders to Pay Twice, W
ALL ST.
J., Jul. 10, 1998, at B1.
13. Levengood, supra note 7, at 415.
14. Bowling, supra note 1, at 680.
15. Levengood, supra note 7, at 415.
16. Id.
17. Id.; W
ONG, supra note 2, at 10. The team also reserves the right to revoke tickets
privileges based on misconduct of the license holder, such as scalping and unsportsmanlike
conduct. G
REEN BAY PACKERS SEASON TICKETS, Season Ticket Holder Policies (on file with
The Saint Louis University Law Journal); S
T. LOUIS RAMS 2006 SEASON TICKET GUIDE, Ticket
Policies & Information
(St. Louis Rams, St. Louis, MO), available at http://www.stlouis
rams.com/Tickets/seasonticketguide.
18. Levengood, supra note 7, at 415.