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The Baltimore Orioles are in the news again

October 20, 2022 | Fiduciary

Not because they are winning (which they are), but because the owner of the baseball club is apparently incapacitated to some degree and his sons are battling over control of the trust that apparently has legal ownership.  Baseball and trust litigation . . . I had to write an article.   

Peter Angelos, the renowned trial lawyer who achieved acclaim related to his representation of victims of asbestos poisoning, purchased the Orioles in 1993 for $173 million, a then record high for sports franchises.  He purchased with a group of investors including notable Marylanders, novelist Tom Clancy, filmmaker Barry Levinson, and tennis star Pam Shriver.  Mr. Angelos was the majority owner.  Despite ascending to one of the most exclusive titles in the world, Mr. Angelos reportedly insisted that that he first be known as “a competent lawyer” and owning the Orioles was “strictly secondary.”  

As an Orioles’ fan, I constantly hear the refrain that the Orioles are “cheap.”  However, I have been quick to remind others that Mr. Angelos had the second highest payroll in the 90’s after he took over – second only to the evil empire, the New York Yankees.  The Orioles also enjoyed success in the regular season including going “wire-to-wire” in 1997 (they were in first place the entire year before losing one round prior to the World Series).  The 2000s, however, were a dumpster fire.  A decade later, in 2012, the Orioles started to turn.  For the next four years, they recorded the most wins in the American League.  From 2017-2021, the team started to resemble the early 2000s again . . . tough to watch.  

2017 is where, according to Mr. Angelos’ youngest son, Lou, the newest story begins.  In lawsuits filed in the Circuit Court for Baltimore County, Lou asserts that Mr. Angelos collapsed due to heart failure and subsequently rapidly experienced mental decline.  In 2017 after the collapse, Mr. Angelos established a revocable trust (the “Trust”) and named himself as Trustee.  His wife, Georgia, and two sons, John and Lou, were named as successor co-individual Trustees.  He also executed a general and financial power of attorney (collectively, the “POA”).  Mr. Angelos’ POA named Georgia as attorney-in-fact, further providing that should Georgia, as attorney-in-fact, fail to act in performing her duties, John and Lou would be appointed to act as attorneys-in-fact, jointly or separately.  Important to this article (and to every baseball fan out there), Mr. Angelos’ interest in the Orioles was transferred to the Trust and he is now incapacitated.  

Lou asserts that due to his father’ declining mental capacity, Mr. Angelos resigned as Trustee in August 2019.  Therefore, Georgia, John, and Lou assumed the role of successor co-individual Trustees.  Apparently, Major League Baseball had some concerns about who was in control over the O’s.  According to John, that led to amendments.  The narrative of Lou’s two lawsuits is driven by numerous provocative and inflammatory allegations generally alleging two things: (1) that John or Georgia have allegedly altered the Trust without authority to do so; and (2) that Georgia has taken a back seat to John in performing her duties under the Trust and POA.  In essence, Lou asserts John’s conduct is an attempt to maintain control over Mr. Angelos’ ownership interest in the Orioles and his Baltimore based law firm, The Law Offices of Peter G. Angelos (“Law Firm”). 

In August 2022, Georgia fired back at Lou’s allegations, filing a separate lawsuit in the Circuit Court for Baltimore County.  Georgia’s lawsuit “pulls back the curtains” allegedly revealing Lou as the bad-actor amongst those involved in the Trust dispute – having allegedly sold Mr. Angelos’ law firm to himself one day before filing his two lawsuits.  According to Georgia’s filing, Lou, as attorney-in-fact for Mr. Angelos, sold the Law Firm to himself for an amount to be determined in the future.  An interesting strategy, to say the least.  

As an estates and trusts litigator, it was of particular interest in how Georgia’s lawsuit incorporated new legislation.  In 2021, Maryland passed the “Statute Against Financial Exploitation” (the “SAFE Act”).  The SAFE Act provides a cause of action (with treble damages) where a person “has committed financial exploitation against [a] susceptible adult or older adult . . .”  Georgia argues that Lou’s alleged unilateral sale of the Law Firm falls under this protected exploitation.  Contrary to Lou’s Complaint, Georgia claims that Mr. Angelos did not wish for the Law Firm to continue past his lifetime.  Georgia’s complaint, in material part, seeks (1) to invalidate the alleged sale of the Law Firm by Lou to himself, (2) to strip Lou of any authority he purports to act on under the POA; and (3) damages in violation of the SAFE Act.

The crux of both Lou and Georgia’s lawsuits appears to heavily depend on the Court’s interpretation of the Maryland Trust Act, regarding one’s authority to alter or amend Mr. Angelos’ Trust.  The Maryland Trust Act provides an initial framework as to a fiduciary’s authority to alter or amend a trust instrument.  In a Motion for Partial Summary Judgment (“Motion”), Lou argues (hypocritically, in light of Georgia’s allegations) that the Trust and POA documents both must expressly authorize the amendment or change.

There are many reasons to provide multiple fiduciaries on trusts, wills and POAs.  However, the downside of doing so is equally evident.  Multiple fiduciaries can lead to the type of intra-family disputes that Lou has decided to take public.  Further, self-interested transactions are obviously questionable, at best. The publicity that this case has taken on by well-accomplished attorneys will provide valuable insight to those interested in fiduciary litigation.  Further, Georgia’s use of the new tool provided by the legislature (the SAFE Act) should provide further insight into how the new cause of action can be yielded.  

While the case has many elements of interest to me, it is an example of an unfortunate dispute between a family going public.  Whether Lou’s decision to take his father’s estate plans public (and to file pleadings with hundreds of pages of vitriolic attacks) was sound legal strategy will be determined in the future.  From my perspective, Lou’s approach seemed targeted to the public and not to winning – I would think that gratuitous and inflammatory language is not going to win over a Court.  Further, Georgia and John’s responses appear to show Lou as the bad actor.  

It is unfortunate that the Orioles positive season is mired by this circus of litigation.  However, if the matter goes to trial, the Baltimore County Circuit Court will be tasked to determine who controls Mr. Angelos’ largest assets, the Orioles and the Law Firm.  Hopefully, I will have front-row tickets. 


12- Declaratory Judgment Lawsuit, Compl. ¶ 67; Assumption of Trust Lawsuit, Compl. ¶ 67. 
13- See e.g., Declaratory Judgment Lawsuit, Compl., pp.39-44 (Count I – Declaratory Judgment, Invalidity of 1st and 2nd [Trust] Amendment, Count II – Intentional Interference with [Lou’s] Inheritance, Count III – Constructive Fraud). 
14- See Declaratory Judgment Lawsuit, Compl. ¶¶ 97-109; see also Assumption of Trust Lawsuit, Compl. ¶¶ 97-109. 
15-Lou’s complaints allege the effect of the amendments to the Trust: “By its terms, the First Amendment purports to authorize [Georgia] to make distributions of Mr. Angelos’ property . . . inconsistent with the intent and express terms of [Mr. Angelos’] estate plan”. Declarator Judgment Lawsuit, Compl. ¶ 205.
16-See Declaratory Judgment Lawsuit, Compl. ¶¶ 1-7; see also Declaratory Judgment Lawsuit, Mot. for Partial Summ. J., p.2 (alleging an “attack on [Mr. Angelos’ estate plan, namely a purported ‘First Amendment’ and ‘Second Amendment’ to his revocable trust”).
17- On August 9, 2022, Georgia filed a lawsuit against Lou: Georgia Angelos v. Louis Angelos, Civil Case C-03-cv-22-003143 (“Georgia Lawsuit”)
18- See Jean Marbella, New Lawsuit: Orioles Owner Peter Angelos’ Son, Louis Angelos, Has Sold His Father’s Law Firm. To Himself., The Balt. Sun (Aug. 9, 2022).
19- Michael W. Davis, Esq., Civil Action with Treble Damages for Exploited Seniors, MSBA (May 31, 2022). 
20- Id.
21- See Jean Marbella, New Lawsuit: Orioles Owner Peter Angelos’ Son, Louis Angelos, Has Sold His Father’s Law Firm. To Himself., The Balt. Sun (Aug. 9, 2022).
22-See Md. Code, Est. & Trusts § 14.5-1006(a)(1
23- See Mot., p.7


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