Conversion

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7^th Circuit Court of Appeals

Case Name: Yehuda Frager v. Indianapolis Colts, Inc.

Case No.: 16-4183

Officials: WOOD, Chief Judge, and POSNER, and KANNE, Circuit Judges.

Focus: Conversion

Yehuda Frager, the plaintiff in this diversity suit (governed by Indiana law) against the Colts for conversion, bought 94 season tickets in 2015. He believed that he would be able to renew those season tickets in 2016, and considers himself to be the rightful owner of 94 season tickets for the 2016 season as a consequence of his having purchased the 2015 season tickets. But the Colts refused to give him season tickets for 2016, precipitating this suit. He claims to own the tickets, that the Colts stole them from him (“converted” them, in polite legal language), and that he is entitled to be reimbursed by the Colts for his loss. The district judge, disagreeing, dismissed the plaintiff’s suit, with prejudice. Frager had a reasonable expectation that he’d be able to renew his season tickets for 2016. That purchasers of season tickets are willing to pay a 30 percent transfer fee in the online marketplace indicates that the expectation of renewal added to the salable value of season tickets, but given the wording of his contract with the Colts it was merely “a speculation on a chance, not a legal right.”

Affirmed

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.