The team owner, who has been bashed from Capitol Hill to Columbus, will make his presentation tonight in Atlanta before a jury of his rarefied peers: two committees of fellow NFL team owners.
The stadium and finance committees heard a presentation two weeks ago from Cleveland city officials, who pressed their case for rejecting the Browns' application to move. Tonight, it's Modell's turn.
"If our rules are to be sustained, it's a slam dunk for us. We have the best case of all," Modell said.
Tomorrow, representatives of the other 29 franchises are expected to take up deliberations on the proposed move and will hear presentations from the team and city. Several owners are predicting a delay in the final vote, from a few weeks to a month or more.
But Modell said he will press for a quick vote, tomorrow or Thursday. League approval is necessary for work to begin on the Baltimore stadium, and a protracted delay could set off a ripple of consequences, from driving up construction and borrowing costs to fueling opposition in Annapolis.
New York Giants co-owner Bob Tisch, a member of the finance committee, said he thinks it is unlikely, but not impossible, for a rapid vote to be mustered so soon after the presentations.
"I think the commissioner [Paul Tagliabue] is not ready to make his recommendation," Tisch said. "We haven't heard from Art yet."
Both sides began arriving yesterday for the meetings. Modell's presentation largely will be delivered by Cleveland attorney Robert C. Weber, who is defending the team against a breach-of-lease suit brought by the city that is scheduled for trial Feb. 12.
Cleveland Mayor Michael White's delegation will include a number of civic leaders, such as Ohio Gov. George V. Voinovich and possibly a senator or two. The delegation has been scheduled for a 90-minute presentation tomorrow before the owners, beginning at 2 p.m. Modell will have an hour rebuttal beginning at 3:30 p.m.
Browns fans were planning bus trips to Atlanta for a series of public events, including a prayer vigil.
White said he also wants a vote as soon as possible, and that may be one of the few areas where he and Modell agree. The league will have to sort out two divergent views of what led up to the team's decision to move, and whether it is justified under NFL guidelines.
The guidelines, instituted by former NFL commissioner Pete Rozelle after a judge found the league's prior rules insufficient under antitrust laws, have nine factors measuring community support, financial distress and good-faith efforts by the team and city to work together.
Modell said the city let him down by building new arenas for its baseball and basketball teams without providing necessary renovation funding for 65-year-old Cleveland Stadium. Years of promises by city and state officials have left him with only missed deadlines, he said.
He is losing money, heavily in debt and convinced that financially strapped Cleveland cannot give him what he needs, he said.
White, however, argued that the city did everything it could and is ready to spend $175 million for a renovation or even a new stadium if the extra $30 million to $100 million can be found for that.
White, who has accused Modell of "sucker-punching" the city by promising not to move and then doing just that, spent three hours earlier this month before the stadium and finance committees. The team owners, many of whom are seeking new venues at home, were blunt in their reaction: a renovation is unlikely to do the trick.
Some owners are skeptical that a thorough renovation can be accomplished for $175 million. The city was asked to look again at building a new facility, and was told that the league may be able to help by waiving visiting-team payouts on some luxury seats or helping to organize a sale of permanent seat licenses to raise money.
League officials have been working behind the scenes on the Browns issue. The public outcry has been overwhelmingly negative. Fans and national observers have seen Modell's move as further evidence of a league more concerned with profit than community loyalty.
Modell had kept Tagliabue informed in recent years about his city's stadium troubles, laying the groundwork for approval. Many in the league think they need to find a way to allow Modell -- a member of the NFL's inner sanctum, who can draw upon decades of favors for support -- to move without opening the floodgates for every team with a gripe to jump on the interstate.
Among the ideas circulating: allowing another team, such as the Tampa Bay Buccaneers or Seattle Seahawks, to move to Cleveland and assume the Browns name, or promising one city or the other an expansion team in the next few years. Some even favor an unusual one-team expansion, putting a team in Baltimore or Cleveland after a new stadium is built.
Modell, who has taken a dim view of past NFL relocations, will try to convince the other owners that his grievances are sufficiently serious, and his treatment by politicians and businesses in Cleveland sufficiently shoddy, to warrant a "yes" vote. He will stress that he would not have given up his home of more than 30 years unless the problems were severe and irreconcilable.
The owners also are keenly aware that their legal standing to block a move is shaky, and losing such cases carries stiff financial penalties.
Cleveland's campaign against Modell -- featuring everything from organized thrashing on the Internet to a mock execution -- has been so strident that some owners may be reluctant to throw their partner back into the lion's den.
"They are not going to get me back there," Modell said of his Cleveland adversaries. "They hung me and my son in effigy."