## Facts

- The City of New York built Shea Stadium at substantial public expense and only after obtaining special legislative authority to lease the facility.
- The City leased Shea Stadium to the New York Mets for baseball, and the Mets’ lease gave the Mets priority in scheduling during the regular baseball season and an additional period in which post‑season games might occur.
- The City separately leased Shea Stadium to the New York Jets (and their predecessor), requiring the Jets to play all home football games after September 1 of each year at Shea Stadium.
- The Jets and the National Football League (NFL) knew of the Mets’ priority rights and the shared-stadium constraints; other NFL teams also shared stadiums with baseball clubs.
- For roughly 13 years, the Jets and the Mets accommodated scheduling needs so the Jets could play home games at Shea without conflicts.
- For the 1977 NFL season, the Jets and the NFL scheduled two Jets home games (September 25 and October 2) on dates when Shea Stadium was not available because of the Mets’ schedule or other preexisting events.
- The Jets sought to play those games at a larger stadium in New Jersey rather than at Shea Stadium.
- The City sued the Jets and the NFL in New York Supreme Court seeking injunctive relief to prevent the Jets’ home games from being played at any location other than Shea Stadium during the lease term.

## Issues

1. Whether the Jets’ lease required the Jets to play all post‑September 1 home games at Shea Stadium, even when the Mets’ priority dates limited Shea’s availability.
2. Whether the City was entitled to a preliminary injunction barring the Jets from playing “home” games at another stadium based on the lease terms and the parties’ longstanding course of performance.
3. Whether the City showed irreparable harm and the inadequacy of money damages, given the public nature and purposes of Shea Stadium.
4. Whether the NFL could be restrained, pending final determination, from scheduling or approving Jets home games in a manner that would result in the Jets’ breach of the Shea Stadium lease.

## Decision

- The court granted preliminary injunctive relief in favor of the City.
- The Jets were restrained from playing scheduled post‑September 1 home games at a stadium other than Shea Stadium in violation of their lease obligation.
- The NFL was restrained, to the extent necessary, from implementing or approving scheduling that would cause or support the Jets’ breach of their Shea Stadium lease.
- The court relied on the lease language, the shared-stadium arrangement known to the Jets and the NFL, and the parties’ long history of accommodating the Mets’ priority schedule when determining that interim equitable relief was warranted.

## Legal Principles

- A preliminary injunction generally requires a showing of likelihood of success on the merits, irreparable harm absent interim relief, and a balance of equities favoring the movant.
- A court may enjoin conduct that would violate a contractual commitment where damages are difficult to measure and the contract is reasonably read to require performance at a specific place.
- The parties’ course of performance over an extended period can be strong evidence of how they understood and carried out contractual scheduling and venue obligations.
- When a municipality builds and operates a stadium under special legislative authority for public objectives, interference with the municipality’s ability to realize those public objectives may support a finding of irreparable harm not fully cured by money damages.
- A party whose actions control or materially influence performance (such as league scheduling and approvals) may be subject to injunctive relief where its conduct would cause or facilitate a contracting party’s breach.

## Conclusion

City of New York v. New York Jets Football Club, Inc. held that the City was entitled to preliminary injunctive relief enforcing the Jets’ lease obligation to play post‑September 1 home games at Shea Stadium, and the court restrained both the Jets and the NFL from carrying out scheduling choices that would move Jets “home” games away from Shea while the merits of the lease dispute remained to be finally decided.


City of New York v. New York Jets Football Club, Inc., 394 N.Y.S.2d 799 (1977)