Do You Have to Win to Get a New Stadium?

We just might be in the era of the professional sports stadium. Several NFL teams have recently either conducted comprehensive renovations on existing stadiums or constructed brand-new, state-of-the-art stadiums. Allegiant Stadium in Las Vegas and SoFi Stadium in Los Angeles both opened as the newest NFL stadiums in 2020.[1] New stadium construction comes at a cost—often a significant cost.

In 2023, the Baltimore Ravens announced a publicly funded $430 million renovation to its stadium.[2] The Jacksonville Jaguars, Buffalo Bills, and Tennessee Titans have since joined the Ravens in planning or constructing new stadiums partially using public funds.[3] The Los Angeles Rams, interestingly, however, privately financed the $5 billion SoFi Stadium.[4] As more teams enter the market for new stadiums, these two competing models for financing—all privately or partially publicly financed—have led to robust debate surrounding the economic costs and benefits to the municipalities and states that house these new facilities.

Perhaps no team is more representative of this debate than the Chicago Bears. The Bears currently play in the oldest stadium in the NFL, Soldier Field.[5] Despite renovations through the years—most recently a 20-month renovation in the early 2000s—the Bears are in search of a new home. They recently purchased lakefront property near Soldier Field in anticipation of a proposed multibillion-dollar lakefront sports and hospitality project. The Burnham Park Project, as it is known, would include the new stadium, a publicly owned hotel, recreational and community spaces, a three-acre promenade and plaza, and retail shops.[6] Like Soldier Field, the new stadium would be publicly owned.

The most contentious issue, as is the case with many public-private stadium partnerships, is the extent of the public contribution. Total cost projections for the Burnham Park Project vary widely, ranging from around $4 billion to around $7 billion.[7] The team has committed to a $2.3 billion contribution, which includes a $300 million loan from the NFL.[8] The remaining costs would be funded by the state, through a combination of refinancing existing debt and an existing hotel tax.[9] Since the project also envisions infrastructure investment, such as public transportation, roads, and utilities, the state would likely be responsible for around $1.5 billion.[10] The Burnham Park Project is one of the most expansive and ambitious NFL stadium projects in recent years.

Not all Illinois stakeholders are enthusiastic about the Burnham Park Project, however. Just this last week, an Illinois State Representative proposed legislation—pointedly titled the Balanced Earnings And Record Standards (BEARS) Stadium Oversight and Expectations Act—that would require any professional sports team seeking public financing to have had a winning record in at least three of the past five regular seasons.[11] The bill’s sponsor, State Representative Bob Morgan, aims for the bill to manage the competitiveness of professional teams and responsible state spending.[12] While the bill would apply to all professional sports teams in Illinois, its namesake is aimed more immediately at the current efforts by the Chicago Bears. Given the team’s record in the past several years, the Bears would not be eligible for public funding under this bill.[13]

The bill is at this point just a proposal. It has not been assigned to a committee for review.[14] Given the financial power, economic leverage, and ease of mobility that professional sports teams can flex, however, the ability of Illinois’s legislature to maintain a close grip on this funding and the Burnham Park Project may be difficult. In the last decade, the St. Louis Rams, Oakland Raiders, and San Diego Chargers relocated to new cities, in part due to conflicts over new stadiums. With the Chicago Bears, it remains to be seen whether you must win to get a stadium.


[1] See Alex Kennedy, What is the Oldest NFL Stadium? Soldier to SoFi in Age, ESPN (Feb. 7, 2025), https://www.espn.com/nfl/story/_/id/39395382/what-oldest-nfl-stadium-soldier-sofi-age.

[2] David A. Lieb, Plans Abounding for New Sports Stadiums Across the US, Carrying Hefty Public Costs, Associated Press (Dec. 23, 2023), https://apnews.com/article/sports-stadiums-public-funding-nfl-mlb-a81d825286530bb95f227efc99f2e9d3.

[3] See id.

[4] Id.

[5] See Kennedy, supra note 1.

[6] See Larry Mayer, Bears Release Plans for Stadium Project in Chicago, Chicago Bears (Apr. 24, 2024), https://www.chicagobears.com/news/bears-release-plans-for-stadium-project-in-chicago.

[7] See Marissa Perlman et al., Chicago Bears Unveil Plan for New Domed Stadium on the Lakefront, CBS (Apr. 24, 2024), https://www.cbsnews.com/chicago/news/chicago-bears-new-domed-stadium-plan-lakefront/; see also Andy Berg, Report: Bears’ Proposed Stadium Would Actually Cost Around $7B, Athletic Business (May 2, 2024), https://www.athleticbusiness.com/facilities/stadium-arena/article/15669974/report-bears-proposed-stadium-would-actually-cost-around-7b.

[8] Perlman et al., supra note 8.

[9] Id.

[10] Id.

[11] Todd Feurer, Illinois Lawmaker Wants to Tie Public Financing for Sports Stadiums to Team Performance, CBS (Feb. 6, 2025), https://www.cbsnews.com/chicago/news/illinois-legislation-public-financing-stadiums-team-performance/.

[12] See Jenna Carroll, ‘BEARS’ Act: Illinois Bill Would Require Teams to Meet Performance Standards for Taxpayer Dollars, FOX 32 (Feb. 10, 2025), https://www.fox32chicago.com/news/bear-act-illinois-lawmaker-would-require-teams-meet-performance-standards-taxpayer-dollars.

[13] Having finished at or below .500 since 2018. See Chicago Bears Franchise Encyclopedia, https://www.pro-football-reference.com/teams/chi/index.htm.

[14] Feurer, supra note 12.

Photo Credit: Chicago Bears – https://www.chicagobears.com/news/bears-release-plans-for-stadium-project-in-chicago.

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