I. The Impact of Stadium Developments on Local Neighborhoods
In the mid-twentieth century in the United States, as city centers were in decline from the loss of industrial jobs and suburbanization, cities sought investment to drive urban redevelopment.1 Central to this goal was the attraction and retention of middle- and high-income households, and to this end local governments financed building projects like tourist districts and shopping malls.2 Along with the prestige of hosting a sports franchise, stadiums are attractive to cities as an anchor of urban redevelopment because they are thought to attract other investments that will collectively revitalize an area.3 While experts differ on the economic impact of stadiums,4 one trend is certain: Stadiums irrevocably alter the neighborhoods in which they are placed, occupying an outsize physical and cultural space.
To acquire land to build a stadium, cities may buy land from local landowners, and if they encounter difficulties in doing so, invoke eminent domain. Eminent domain is the power of the government to take privately owned land and convert it to public use, providing the landowner with reasonable compensation under the Fifth Amendment. Courts have consistently upheld the condemnation of land for new stadiums as a valid use of eminent domain.5 While the use of eminent domain to build stadiums directly displaces the original residents, stadium projects that have not invoked eminent domain also have a significant impact on the neighborhoods in which they are placed. Stadiums can fundamentally change the character of a neighborhood through the increase of property values or the building of new transit routes to and from the stadium, which alters the types of residents who are attracted to an area.6 Over time, the influx of increasingly higher-income residents and businesses serving their needs can transform a formerly working-class community. The following is an examination of the impact of two stadium projects in Los Angeles: the building of Dodger Stadium in the former neighborhood of Chavez Ravine, and the building of the Rams Stadium currently underway in Inglewood.
II. Los Angeles Before the Dodgers
“There’s an old Mexican custom that where you’re born, the umbilical cord is buried. Mine’s buried under third base . . . . And I hate home runs, ’cause every time they step on third base, my stomach hurts.” – Lou Santillan, former resident of Chavez Ravine7
In the years before the building of Dodger Stadium, downtown Los Angeles comprised business districts surrounded by multiracial working-class communities.8 An iconic downtown neighborhood, Bunker Hill was a colorful mix of Latinx, Black, and other working-class communities.9 However, as historian Jerald Podair characterizes it, downtown remained a “work-and-flee zone” for the white middle-class, a place where they worked by day and fled by night.10 When Brooklyn Dodgers’ owner Walter O’Malley first considered moving the team to Los Angeles, the promise by the city was to build a world-class stadium, “the wonder of the baseball world.”11 Supporters envisioned Dodger Stadium as helping remake Los Angeles in the image of a more modern metropolis—with a downtown combining business, culture, and leisure, alongside middle- and upper-class neighborhoods. As the Dodgers pondered moving to Los Angeles, however, not everyone held the same vision for the city. Podair writes, “Dodger Stadium became the locus for an argument between those who envisioned Los Angeles as an everyday city of neighborhoods and services and others who saw it as a modern, growth-focused city.”12
Among the communities that comprised Los Angeles before the arrival of the Dodgers was Chavez Ravine, a small village in the heart of the city. Overlooking downtown, Chavez Ravine was three hundred acres of unpaved roads, homes with garden plots, and roaming sheep and cattle.13 The community of one thousand families was designated a slum by the city in the 1930s.14 Many of the families that lived there had been redlined and prevented from moving into other neighborhoods in the city.15 What Chavez Ravine lacked in luxury, it made up in the sense of community among the majority Mexican American families who lived there. When families in Chavez Ravine held quinceañeras and weddings, the whole neighborhood was invited.16
In the early 1950s Chavez Ravine was scouted as a site for a federally funded public housing project.17 The city planned to use the land under the authority of the 1949 Federal Housing Act and promised that the neighborhood’s residents would be able to return to the new housing units.18 Some families left, while the city used eminent domain to forcefully evict others. Eventually, the political will to build the project dissipated, and the city bought back the land from the Federal Housing Authority. For years after, Chavez Ravine sat in a state of limbo with only a handful of residents who had remained, holding out in the neighborhoods they had grown up in.19
III. Political and Legal Obstacles to Dodger Stadium and the Battle for Chavez Ravine
Walter O’Malley was first drawn to Chavez Ravine as a potential site for the Dodgers’ stadium due to its central location and the proximity of a number of major freeways.20 After considerable negotiations with city officials, City Council approved a proposal to the Dodgers that would include about three hundred acres of Chavez Ravine in exchange for Wrigley Field, which O’Malley had earlier acquired.21 Supporters of the stadium agreement stressed the economic benefits and tax revenue that would be generated by putting Chavez Ravine on the tax rolls and enabling it to stimulate local businesses.22 Opponents argued that the city deserved “a more equitable contract.”23 In December of 1957, opponents gathered enough signatures on a petition to place the Chavez Ravine agreement to a public referendum.24 In June 1958, the stadium agreement was upheld by voters by a slim margin.25
Around this time, another strategy emerged to block the stadium deal: Taxpayers filed two lawsuits challenging the contract transferring the land at Chavez Ravine.26 Federal law required the city to reserve the land of Chavez Ravine for an appropriate public purpose after the public housing project had been abandoned.27 The legal question was whether a baseball team and its privately owned stadium could qualify as a public purpose under the Federal Housing Act, the meaning of which had been disputed by officials for years.28
On July 14, 1958, Judge Praeger of Los Angeles Superior Court issued a decision,29 concluding that despite the benefits which might come to the city in the form of tax revenues, stimulus to local businesses, and the achievement of “major league” status for the city, the primary beneficiary of the agreement was still a privately owned entity, and thus the Chavez Ravine contract was invalid.30 O’Malley appealed the decision along with the City.31
On January 13, 1959, the California Supreme Court ruled 7-0, upholding the original contract between the City and the Dodgers. Chief Justice Phil Gibson wrote, “[W]e must view the contract as a whole, and the fact that some of the provisions may be of benefit only to the baseball club is immaterial, provided the city receives benefits which serve legitimate public purposes.”32 This decision marked a dramatic turn in over a decade of “legal and public policy debate over the question of whether a privately constructed baseball stadium fulfilled a public purpose.”33 The high court permitted “public purpose” to be interpreted in a way that could grant substantial private gain, and gave “sanction to the idea that the city could partner with business” to not only create a climate that “benefited private entities generally,” but to “assist specific businesses that in the view of city officials promoted a public purpose.”34
After this decision, on May 8, 1959, the city moved to forcefully evict the few remaining residents of Chavez Ravine.35 Bulldozers tore through the last homes in the neighborhood, and some families were dragged out of their homes by sheriff deputies.36 Aurora Vargas, who had lived in Chavez Ravine for thirty-five years, was carried “kicking and screaming from the premises.”37 Her mother, Avrana Arechiga, threw rocks at the sheriff deputies.38
Images from that day were broadcast widely across Los Angeles, and May 8 became known as “the day of infamy.”39 The evictions at Chavez Ravine would leave a bitter memory in the Latinx community of Los Angeles40 and a disputed and controversial legacy across the wider city. Not long after May 8, the land of Chavez Ravine was entirely cleared.
IV. Moving the Rams into Inglewood
The deal to build Dodger Stadium in the heart of Los Angeles would pave the way for future stadium projects to come as symbols of urban progress. In 2015, nearly sixty years after Dodger Stadium was built, the National Football League announced that the Rams team was leaving St. Louis for Los Angeles and would be housed in a newly constructed stadium built in Inglewood, California.41 The stadium is estimated to cost $2.6 billion, and it will be built on land formerly occupied by the Hollywood Racetrack.42 Named the Los Angeles Stadium at Hollywood Park, the massive complex will span 298 acres and will feature entertainment, office and residential space, a hotel and public park.43
Inglewood sits in one of the last remaining affordable and well-located areas in the Los Angeles Basin.44 Like the former area of Chavez Ravine, Inglewood caught the eye of developers because of its convenient location near major freeways, the growing tech industry and the airport, along with the incoming light rail development which will connect the city to downtown Los Angeles.45 Inglewood, however, is a historically working-class African-American city with references throughout rap and hip-hop. As of the 2017 Census, Inglewood had an estimated 43 percent Black population, 50 percent Latinx, and a very small percentage of white residents.46
With the enormous change underway, Inglewood’s longtime residents worry that the stadium development will transform the area’s existing community. Unlike the displacement of residents at Chavez Ravine, the land occupied by the future Rams stadium does not directly displace residents. However, the ripple effects of increasing property values will likely have a substantial and lasting impact. 47 In just a year since the Rams’ move was announced, the median cost of a home in Inglewood has gone up 12 percent from 2016 to 2017.48 Already, longtime residents have begun noticing a shift in the racial makeup of their neighborhoods.49 In May 2017, a developer bought eighteen acres near the stadium to build a gated community to appeal to “Los Angeles County’s highly educated tech workers.” It may not be long before the Inglewood mentioned in rapper Tupac’s classic hit “California Love” as an iconic west coast neighborhood will no longer be recognizable.
Many neighborhoods in Los Angeles, says UCLA Ziman Center for Real Estate Executive Director Tim Kawahara, have experienced the displacement of longtime residents who are priced out, including Echo Park, Silver Lake, and Highland Park, among others.50 Kawahara writes, “[M]any speculative investors have placed a sharp focus on [Inglewood.] Sixty-four percent of Inglewood residents are renters who will not experience increased home equity through price-appreciation, and will at the same time face significant rent increases.”51 The influx of capital into an area has been noted to differently affect homeowners and renters, particularly low-income ones, presenting the latter with fewer options for staying in an area.52 Historically, Black and Latinx households are about twice as likely to rent their homes than whites,53 and these differences are attributed to lower income, lack of accumulated intergenerational wealth, and discriminatory housing barriers.54 The Black and Latinx residents who are homeowners in Inglewood may also face an increased pressure to sell when property values rise, due to the same conditions of lacking sufficient income and family wealth.
Ultimately, major development projects come down to competing visions for a city. Unlike Chavez Ravine, which once belonged to a community that was evicted for the building of a public housing project, the Rams stadium does not sit on land reserved for a public purpose. As such, the Rams stadium development does not require voter referendum or court approval to be built. However, the impact of the stadium development and private investment in Inglewood will significantly affect the communities around it, most of whom are Black, Brown, and low-income.55 The displacement in Inglewood may not be as sudden as the evictions at Chavez Ravine, but they are evocative of a pattern for poor communities of color in Los Angeles that are gradually being forced out of the places they once called home.
[1] Eric Joseph van Holm, Left on Base: Minor League Baseball Stadiums and Gentrification, 54 Urb. Affs. Rev. 632, 635 (2018).
[2] Id.
[3] Id. at 636.
[4] Compare Robert A. Baade & Richard F. Dye, The Impact of Stadiums and Professional Sports on Metropolitan Area Developments, 21 Growth & Change: J. Urb. & Regional Pol’y 1, 13 (1990) (“The evidence presented here is that the presence of a new or renovated stadium has an uncertain impact on the levels of economic activity and possibly a negative impact on local development relative to the region.”), with Arthur C. Nelson, Locating Major League Stadiums Where They Can Make a Difference, 7 Pub. Works Mgmt. & Pol’y 98, 108 (2002) (“As a general proposition, metropolitan economies appeared to do better when major league teams played anywhere in the central city but do poorly when major league teams played in the suburbs.”)
[5] See Peter Montine, Forced Turnovers: Using Eminent Domain to Build Professional Sports Venues, 9 Wash. J.L. Tech. & Arts 331, 333 (2014).
[6] See Xia Feng & Brad Humphreys, Assessing the Economic Impact of Sports Facilities on Residential Property Values: A Spatial Hedonic Approach, 19 J. Sports Econ. 188, 206 (2018) (“The results show that the presence of both facilities has a significant positive effect on the value of surrounding houses and this positive effect decreases as the distance from the facilities increases.”); Stan Paul, If You Build It, Will They Have to Leave?, UCLA Newsroom (Aug. 29, 2016), http://newsroom.ucla.edu/releases/if-you-build-it-will-they-have-to-leave (“Areas around transit stations are changing and many of the changes are in the direction of neighborhood upscaling and gentrification.”); Charles C. Tu, How Does a New Sports Stadium Affect Housing Values? The Case of FedEx Field, 81 Land Econ. 379, 393 (2005).
[7] See Hector Becerra, Decades Later, Bitter Memories of Chavez Ravine, L.A. Times (Apr. 5, 2012), http://articles.latimes.com/2012/apr/05/local/la-me-adv-chavez-ravine-20120405/.
[8] See Jerald Podair, How the Dodger Baseball Stadium Shaped LA—and Revealed Its Divisions, Guardian (Apr. 12, 2017, 2:30 PM), https://www.theguardian.com/cities/2017/apr/12/dodger-baseball-stadium-shaped-la-and-revealed-its-divisions.
[9] See id.
[10] See id.
[11] See Jerald Podair, City of Dreams: Dodger Stadium and the Birth of Modern Los Angeles xi (Princeton Univ. Press 2017).
[12] Id. at xiii.
[13] Becerra, supra note 7.
[14] Janice Llamoca, Remembering the Lost Communities Buried Under Center Field, NPR: Code Switch (Oct. 31, 2017, 7:20 PM), https://www.npr.org/sections/codeswitch/2017/10/31/561246946/remembering-the-communities-buried-under-center-field.
[15] See Elina Shatkin, Remembering Dodger Stadium When It Was Chavez Ravine, KPCC (Oct. 31, 2017), https://www.scpr.org/news/2017/10/31/77135/remembering-dodger-stadium-when-it-was-chavez-ravi/.
[16] See Llamoca, supra note 14.
[17] Podair, supra note 8.
[18] Becerra, supra note 7.
[19] See Nathan Masters, Chavez Ravine: Community to Controversial Real Estate, KCET (Sept. 13, 2012), https://www.kcet.org/shows/lost-la/chavez-ravine-community-to-controversial-real-estate.
[20] Neil J. Sullivan, The Dodgers Move West 96–97 (Oxford Univ. Press 1987).
[21] Id. at 101.
[22] Id. at 100.
[23] Id. at 153.
[24] Id. at 138.
[25] Id. at 160.
[26] Id. at 154, 162; see Ruben v. City of Los Angeles, No. 687210 (Cal. Super. Ct. 1958), aff’d in part, rev’d in part 337 P.2d 825 (Cal. 1959).
[27] Sullivan, supra note 20, at 105.
[28] Id. at 162.
[29] See Ruben, No. 687210, at *1 (Cal. Super. Ct. 1958).
[30] Sullivan, supra note 20, at 168.
[31] Id. at 169.
[32] Id. at 173; City of Los Angeles v. Superior Court of Los Angeles Cty., 333 P.2d 745 (Cal. 1959).
[33] Podair, supra note 11, at 147.
[34] Id. at 148–49.
[35] Llamoca, supra note 14.
[36] Id.
[37] Sullivan, supra note 20, at 179.
[38] Id.
[39] Podair, supra note 8.
[40] See Becerra, supra note 7, at 181.
[41] Ken Belson, Rams Moving to Los Angeles Area, and Chargers Could Join Them, N.Y. Times (Jan. 12, 2016), https://www.nytimes.com/2016/01/13/sports/football/rams-moving-to-los-angeles-area-and-chargers-could-join-later.html.
[42] Nathan Fenno & Sam Farmer, Los Angeles Rams Break Ground on $2.6-billion Inglewood Stadium, “New Era” of NFL, L.A. Times (Nov 17. 2016, 5:50 PM), http://www.latimes.com/sports/rams/la-sp-rams-ground-breaking-20161117-story.html.
[43] Brian Bencomo, How the Rams’ Stadium Development Could Impact Inglewood, KCET (Jan. 16, 2018), https://www.kcet.org/shows/town-hall-los-angeles/how-the-rams-stadium-development-could-impact-inglewood.
[44] Tim Kawahara, The Coming Transformation of South L.A. and Inglewood, UCLA Anderson Blog (Apr. 27 2016), http://blogs.anderson.ucla.edu/anderson/2016/04/the-coming-transformation-of-south-la-and-inglewood.html.
[45] Id.
[46] QuickFacts: Inglewood City, California, U.S. Census Bureau,
https://www.census.gov/quickfacts/fact/table/inglewoodcitycalifornia/PST045217#qf-headnote-a (last visited Sept. 9, 2018); Inglewood, CA, Data USA, https://datausa.io/profile/geo/inglewood-ca/ (last visited Aug. 16, 2018).
[47] Several studies highlight the increase in property values that occur in the proximity of a new stadium. See generally supra note 6.
[48] Id.
[49] Erin Aubry Kaplan, Whites Are Moving Back to Inglewood. There Goes Our Neighborhood., L.A. Times (Nov. 26, 2017, 5:00 AM), http://www.latimes.com/opinion/op-ed/la-oe-kaplan-inglewood-gentrification-20171126-story.html.
[50] See Kawahara, supra note 44.
[51] Id.
[52] See Stuart Gabriel, Tim Kawahara & Stephen Oliner, The Coming Transformation of South L.A. and Inglewood: A Community Forum, UCLA Econ. Letter (UCLA Anderson Forecast & UCLA Ziman Ctr. for Real Estate, Los Angeles, Cal.), Apr. 2016, at 2, https://www.anderson.ucla.edu/Documents/areas/ctr/ziman/UCLA_Economic_Letter_Gabriel-Kawahara-Oliner_04.08.16.pdf.
[53] Anthony Cilluffo, Abigail Geiger & Richard Fry, More U.S. Households Are Renting Than at Any Point in 50 Years, Pew Research Ctr.: Fact Tank (July 19, 2017), http://www.pewresearch.org/fact-tank/2017/07/19/more-u-s-households-are-renting-than-at-any-point-in-50-years/.
[54] Christopher E. Herbert et al., U.S. Dep’t of Hous. & Urb. Dev., Homeownership Gaps Among Low-Income and Minority Borrowers and Neighborhood 166–68 (2005), https://www.huduser.gov/Publications/pdf/HomeownershipGapsAmongLow-IncomeAndMinority.pdf.
[55] Since news of the stadium development, local residents and community activists have attempted to place rent control on the ballot for Inglewood in 2018. The effort fell short when not enough valid signatures were obtained, but activists vow to continue fighting. Elijah Chiland, Rent Control Measures Fall Short in Inglewood, Long Beach, and Pasadena, Curbed: L.A. (June 25, 2018, 10:23 AM), https://la.curbed.com/2018/6/22/17442778/rent-control-inglewood-long-beach-pasadena.