Pittsburgh Baseball, Inc. v. Stadium Auth. of the City of Pittsburgh

In Pittsburgh Baseball, Inc. v. Stadium Auth. of the City of Pittsburgh, 157 Pa. Commw. 478, 630 A.2d 505 (Pa. Cmwlth. 1993), the Court noted the cases supporting ratification by municipal inaction, "appear to have a common denominator; namely, that municipal inaction plus the acceptance of benefits under the contract may constitute ratification." Id. at 509 In Pittsburgh Baseball, the Court concluded the city's receipt of indirect benefits to be insufficient to support ratification by nonaction. There, the plaintiff sought enforcement of an oral promise by the city's mayor to provide significant financial assistance in exchange for plaintiff's agreement to purchase the Pittsburgh Pirates baseball team. The plaintiff argued the city received benefits from the agreement in the form of taxes on ticket sales and fan spending on local goods and services. The Court concluded this did not constitute a direct benefit because, "clearly, it is the Pirates' fans, and not the plaintiff, that pay the taxes on ticket sales and make the other expenditures." Id. at 510. Accordingly, the Court determined there could be no ratification by nonaction where the city received only an indirect benefit from the disputed agreement. The Court explained that: "Quasi-contracts are contracts which are implied in law for reasons of justice"