History of the National Hockey League/1917–1942/Origins/Eddie Livingstone/Later court battles

Throughout the NHL's first decade, Eddie Livingstone continued to press his claim to the Toronto franchise in court. On October 18, 1923, the Supreme Court of Ontario awarded Livingstone $100,000 in damages. St. Patricks owner Charlie Querrie made numerous attempts to prevent Livingstone from collecting on his awards. In 1923, he transferred the ownership of his team to his wife, Ida, making her the first female owner in ice hockey history. The $100,000 award was later reduced, causing Livingstone to appeal to the highest court in the British Empire, the Judicial Committee of the Privy Council in London, England; the court denied his claim.

Despite the reduced awards, the Querries found the pressures of meeting their obligations to Livingstone too great and, as a result, placed the St. Patricks up for sale in 1927. On February 14, 1927, the St. Patricks were sold to a group represented by Conn Smythe for $160,000 despite a potentially greater offer from a Philadelphia-based group. Among the first moves Smythe made was to rename his team the Toronto Maple Leafs.