Haslams amend complaint in federal court

Haslam Sports Group (HSG), owner of the Cleveland Browns, submitted an amended complaint in an existing federal lawsuit against the city of Cleveland which is seeking to keep the Browns from moving to suburban Brook Park. In announcing its filing today, HSG said the city is “misguiding” its residents.
In challenging the city’s assertions, HSG touted the benefits of its planned, enclosed stadium and supportive development in Brook Park. And it opted to also take some shots at Cleveland city officials at the same time. HSG appears to be winning support from state lawmakers for earmarking state tax revenues generated by the stadium to service stadium construction bonds.
HSG representatives said their proposed stadium and mixed-use development would be only one mile from the Cleveland city limits. Yet, it would be “relieving Cleveland of any stadium-related taxpayer expenses” while not touching Brook Park’s existing tax revenues.
They said the stadium’s location would be “in the heart of the Greater Cleveland metropolitan area.” HSG added that the location is particularly important with 85 percent of home-game attendees living outside Cleveland’s city limits.
“Despite the new stadium’s significant benefits, the city of Cleveland has been misguiding Clevelanders by inaccurately conflating the Brook Park project with Art Modell breaking a lease and moving a team to an entirely different state,” the HSG statement read.
“The city has done so by invoking the so-called Modell Law — an Ohio law passed in the 1990s in response to the relocation of the Browns out of Ohio — to try and halt the project,” today’s statement added.
Ted Tywang, HSG’s chief administrative officer and general counsel said the city has never explained how the Modell Law could sensibly apply to the Browns. In 1995, the Browns owner at that time, Art Modell, moved the team to Baltimore while it was in the middle of a lease at the former Cleveland Municipal Stadium.
He said the Browns will continue to play games in its 1999-built downtown lakefront stadium until the expiration of its lease after the 2028 season. And he noted that the Browns owners have committed to keeping the team in the Cleveland area long after the lease expires.
“In fact, the Haslams’ proposed unprecedented private investment in a world-class stadium and surrounding development, and their continued unwavering commitment to Northeast Ohio, are the complete opposite of the Modell situation,” Tywang said in a written statement.
He also noted that 10 of 32 NFL teams play their home games in metropolitan areas outside of the city they represent. Others like the Chicago Bears have sought to move to the suburbs. And several more do not play in stadiums located downtown — they are at the edge of the city limits but just barely inside the corporate boundary.
“So our proposal is entirely consistent with other hometown teams across the country,” Tywang said. “Our actions in court are intended to ensure that the city’s irresponsible and baseless attempt to apply the Modell Law to the Browns does not slow our momentum to build a world-class stadium right here in Northeast Ohio for the Browns, our fans and the entire region.”
NEOtrans reached out to Cleveland Press Secretary Marie Zickefoose for a reply and comment but had not yet heard back from her prior to publication of this article. NEOtrans broke the story in February 2024 that HSG was seeking to acquire 176 acres of land on Snow Road near Interstate 71 for a new stadium.
HSG reps claim their filing today affirms that – far from running from the Cleveland area – HSG is reinforcing its commitment and increasing its investment in the region in an unprecedented way.
In making that argument, HSG, together with its development partners, is committing to invest more than $2 billion in private capital in the proposed new stadium and the adjoining mixed-use development, with the total project representing $3.4 billion in economic development.
The $2 billion includes an investment of at least $1.2 billion from the Haslam family/HSG towards construction of the enclosed stadium plus any cost overruns, marking the “largest per capita private sports facility investment in U.S. history,” the Haslams claim.
“The Cleveland Browns and our community need and deserve a new home – and from the outset we have been unequivocal that it must positively benefit our community and Northeast Ohio,” said the Browns’ owners, Dee and Jimmy Haslam.
“The proposed Huntington Bank Field in Brook Park meets this vital objective and will reflect positively on our world-class region and its promising future. It also reflects our 100-percent commitment to keeping the Browns in their home market for generations to come.”
In addition to its longtime local counsel, Thompson Hine LLC, HSG has engaged the firm of Wachtell, Lipton, Rosen & Katz as it seeks to expeditiously resolve this matter and break ground in Brook Park in 2026.
The centerpiece of the project will be a state-of-the-art enclosed stadium for the Browns – consistent with other world-class NFL stadiums – that can host major year-round events.
The new stadium, which would sit less than a mile from Cleveland city limits, would also anchor a mixed-use development to catalyze meaningful economic impact for Cleveland and the surrounding region.
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