“The purchase of a ticket to a sports or entertainment event typically creates nothing more than a revocable license.” —Greenberg, Judge 

Facts Yarde Metals, Inc. (Yarde) was a season ticket holder to New England Patriots professional home football games. The football team is owned by the New England Patriots Limited Partnership (Patriots). Yarde permitted a business associate to attend a Patriots game. However, the associate was ejected from the game for disorderly conduct. Subsequently, the Patriots sent Yarde a letter terminating his season ticket privileges in the future. Yarde sued the Patriots, claiming that the Patriots had breached his implied contractual right to purchase season tickets. The Patriots countered that the Patriots’ written contract with season ticket holders expressly provided that the “purchase of season tickets does not entitle purchaser to renewal in a subsequent year.” The Patriots asserted that because the contract with Yarde was an express written contract, Yarde’s claim of an implied right to purchase season tickets in the future was parol evidence and was inadmissible to change the express terms of the contract. The trial court dismissed Yarde’s case. Yarde appealed. 

Issue: Does Yarde have an implied right to purchase Patriots’ season tickets? 

Language of the Court: The purchase of a ticket to a sports or entertainment event typically creates nothing more than a revocable license. The ticket specifically stated that “purchase of season tickets does not entitle purchaser to renewal in a subsequent year.” Parol evidence is not generally admissible to vary the unambiguous terms of the contract. Yarde has articulated no basis on which we can ignore the language on the ticket. 

Decision: The appeals court held that there was an express written contract between Yarde and the Patriots, and that the parol evidence rule prevented Yarde’s alleged implied right to purchase season tickets from becoming part of that contract. The appeals court affirmed the trial court’s dismissal of Yarde’s case. 

Ethics Questions: Was it ethical for the Patriots to terminate Yarde’s season ticket privileges? What would be the consequences if there were no parol evidence rule?