The suit was filed Wednesday in St. Louis Circuit Court, one day after NFL owners voted to allow the Rams to relocate to suburban Los Angeles for next season.
The suit alleges that Kroenke and Chief Operating Officer Kevin Demoff made false and misleading statements over the years indicating the team had no intention of leaving St. Louis, violating Missouri's Merchandising Practices Act.
The law prohibits false statements in the sale or advertisement of trade or commerce. The suit claims the Rams violated the law in connection with the sale of tickets and merchandise.
Messages seeking comment from the Rams were not returned.
The suit was filed by James Pudlowski, Louis Cross III, Gain Henry and Steve Henry, and was the first lawsuit stemming from the Rams' departure. Among the statements in the lawsuit:
• Demoff was asked after Kroenke's purchase of land in Inglewood about the Rams' future and said, "I expect it will be right here in St. Louis." The Inglewood site is where Kroenke plans a $2-billion-plus stadium expected to open in 2019.
Kroenke said in a 2010 interview, "It's not our desire to ever lead the charge out of St. Louis. … I'm going to attempt to do everything I can to keep the Rams in St. Louis."
"Defendants did in fact 'lead the charge' out of St. Louis, yet defendants never informed their ticket and merchandise buyers or corrected the previous statements," the lawsuit says.
The St. Louis Regional Convention and Sports Complex Authority, which spent more than $16 million on plans for a new riverfront stadium that the NFL eventually deemed unacceptable, could also sue. The co-chairmen of the task force that led that effort declined to speculate on the possibility of legal action.
The NFL has announced the Rams' pending move to Los Angeles, but the domain name that carries the team name for the Rams' former and future home base resides in South Dakota's Black Hills.
Rapid City used-car salesman Brian Busch tells the Argus Leader newspaper that he bought the www.losangelesrams.com domain name in 1997, two years after the team packed up and moved to St. Louis.
He grew up rooting for the Rams, and thought he might build a fan site, but never did.
The domain name, which is structured like some domain names for other NFL teams, has suddenly become more valuable with team owners' voting Tuesday to allow the Rams to relocate to Inglewood.