Aldeman v. General Motors Acceptance Corp. (In Re Tulsa Port Warehouse Co.)

4 B.R. 801, 29 U.C.C. Rep. Serv. (West) 1608, 1980 U.S. Dist. LEXIS 13059
CourtDistrict Court, N.D. Oklahoma
DecidedMay 28, 1980
DocketBankruptcy 79-C-354-BT
StatusPublished
Cited by20 cases

This text of 4 B.R. 801 (Aldeman v. General Motors Acceptance Corp. (In Re Tulsa Port Warehouse Co.)) is published on Counsel Stack Legal Research, covering District Court, N.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aldeman v. General Motors Acceptance Corp. (In Re Tulsa Port Warehouse Co.), 4 B.R. 801, 29 U.C.C. Rep. Serv. (West) 1608, 1980 U.S. Dist. LEXIS 13059 (N.D. Okla. 1980).

Opinion

OPINION

BRETT, District Judge.

Defendants-Appellants, General Motors Acceptance Corporation (GMAC) and Chuck Naiman Buick Company (Naiman), appeal to this Court for reversal of judgment entered by the Bankruptcy Court on March 13, 1979. That judgment and the accompanying Findings of Fact and Conclusions of Law held that leases involving four automobiles were as a matter of law leases intended for security and thus subject to the perfection requirements of the Uniform Commercial Code. It was further held that since these security agreements had not been perfected as required by the U.C.C., the interest of the plaintiff trustee in bankruptcy in the subject automobiles or the proceeds is superior to that of the general creditor defendants, GMAC and Naiman.

After carefully considering the substance of the agreements and the applicable law, the Court- finds that the judgment of the Bankruptcy Court should be affirmed.

During 1976 and 1977, the Bankrupt in this case entered into four separate “Non-Maintenance Lease Agreements” with Nai-man, which were assigned to GMAC. The four agreements are identical in all pertinent respects.

The leases here involved are “open-end” leases which are distinguished from “closed-end” leases primarily by the method of termination as provided in Items 30 and 31 of the agreements. 1 The agreements provide that in a closed-end lease, at the end of the *803 lease term, the lessee returns the vehicle to lessor and the obligations of both come to an end. Further, if the lease is terminated prematurely, the lessee is responsible for the unpaid rental with the vehicles being returned to lessor.

In an open-end lease, the termination provisions are somewhat more complex, Here, at the end of the lease term, the lessee is to return the vehicles to the lessor, However, unlike the situation involving a closed-end lease, the relationship between *804 lessor and lessee does not come to an end. Rather, the lessor, upon return of the vehicle, must sell the vehicle, and if the net amount received from the sale is greater than the predetermined “agreed depreciated value”, lessor must pay any excess to the lessee. On the other hand, if the net amount received is less than the “agreed depreciated value”, lessee must pay to lessor the deficiency.

In case of premature termination, by default or choice of lessee, the lessee must also return the vehicle and the lessor must sell it. However, the “agreed depreciated value” is adjusted to determine the “maximum amount of open end lessee liability,” and then lessee will either receive a refund or be required to pay a deficiency, based upon the net sale price. The “net amount” in either event is defined as the sale price of the vehicle less costs to the lessor in connection with the sale and all debts incurred by lessee which might constitute a lien on the vehicle or a liability to the lessor.

The face of each agreement contains a section entitled “Lessee Liability Disclosure: (must be completed if this is an open-end lease).” In this section, the amounts for which lessee will be responsible are computed. The computation begins with the Original Value of the vehicle, from which is deducted any Cash Down Payment and or net trade-in, to arrive at the Net Original Value. In these particular leases, the original value and the net original value are the same, since there is no down payment or trade-in. The next item is designated Agreed Depreciated Value, and is an estimate of the value of the vehicle at the end of the lease term. This Agreed Depreciated Value is deducted from the Net Original Value, and the difference is designated as Total Amount of Fixed Monthly Rentals for the Full Lease Term to be Credited Against Original Value. The final item (numbered 6A) in the section is Total Amount of Fixed Monthly Rentals Not to be Credited Against Original Value. 2 There is no explanation of the method by which Item 6A is computed.

Items 6 and 6A are then totaled and sales tax added to arrive at total monthly charges for lease term. This amount is then divided by the number of months of the lease term to arrive at the monthly rental payment.

Determination of the nature of these agreements must begin with Title 12A O.S. § 1-201(37), which defines the term “security interest.” 3 This section clearly states *805 that whether a particular lease is intended for security is to be determined by the facts of each case. The section then goes on to provide guidelines in the case of a lease with an option to purchase. However, the leases involved here do not include options to purchase, so the guidelines referring to such options and the tests concerning nominal or substantial consideration are not applicable.

Neither is the absence of an option to purchase controlling. As the Court observed in In The Matter of Tillery, 571 F.2d 1361 (5th Cir. 1978):

“Just as the inclusion of an option to purchase does not in and of itself make the lease one intended for security; so also, the exclusion of such an option does not ipso facto make it a ‘pure lease.’ ”

Whether an agreement is a lease intended for security is dependent on the intent of the parties as ascertained from the terms of the instrument. The fact that these agreements are denominated as leases is not a controlling factor. Stanley v. Fabricators, Inc., 459 P.2d 467 (Alaska 1969).

It is substance and not form which is decisive in determining whether an agreement is intended to create a security interest. In Re A & T Kwik-N-Handi, Inc., 13 UCCRS 960 (D.C.Ga.1973). Therefore, the Court must analyze the contract to determine what rights and obligations have been created. Uniroyal, Inc. v. Michigan Bank, N.A., 12 UCCRS 745 (Mich.1972). In other words, the real test is what the contract actually does, rather than what it superficially says.

A careful look at these agreements reveals that they are indeed leases intended for security. The only interests retained by the lessor are naked title, plus the right to receive the purchase price and an amount which is apparently interest.

Under these agreements the parties have consented at the outset how much lessor is to realize from the sale of the vehicles. He is to receive from the lessee the agreed monthly payments which include interest. The remainder of the price is then obtained by sale of the vehicle at termination.

It is the lessee who has the real interest in the disposition of the vehicle. Lessor is assured by the agreement of the lessee that he will receive the original agreed value of the vehicle—no more and no less—plus an amount that is apparently interest. (Emphasis supplied).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stevenson v. Becker
N.D. California, 2024
In Re Grubbs Construction Co.
319 B.R. 698 (M.D. Florida, 2005)
In Re Damron
275 B.R. 266 (E.D. Tennessee, 2002)
Michaels v. Ford Motor Credit Co. (In Re Michaels)
156 B.R. 584 (E.D. Wisconsin, 1993)
Wheels, Inc. v. Otasco, Inc. (In Re Otasco, Inc.)
196 B.R. 554 (N.D. Oklahoma, 1991)
Wheels, Inc. v. Otasco, Inc. (In Re Otasco, Inc.)
111 B.R. 976 (N.D. Oklahoma, 1990)
Woodson v. Ford Motor Credit Co. (In Re Thompson)
101 B.R. 658 (N.D. Oklahoma, 1989)
In Re Aspen Impressions, Inc.
94 B.R. 861 (E.D. Pennsylvania, 1989)
In Re Sprecher Bros. Livestock & Grain, Ltd.
58 B.R. 408 (D. South Dakota, 1986)
Woodson v. Tom Bell Leasing (In Re Breece)
58 B.R. 379 (N.D. Oklahoma, 1986)
Taylor Rental Corp. v. Deere (In Re Noack)
44 B.R. 172 (E.D. Wisconsin, 1984)
In Re Loop Hospital Partnership
35 B.R. 929 (N.D. Illinois, 1983)
In Re Tucker
34 B.R. 257 (W.D. Oklahoma, 1983)
In Re Niemi
27 B.R. 215 (D. Oregon, 1982)
In Re National Welding of Michigan, Inc.
17 B.R. 624 (W.D. Michigan, 1982)
In Re Peacock
6 B.R. 922 (N.D. Texas, 1980)

Cite This Page — Counsel Stack

Bluebook (online)
4 B.R. 801, 29 U.C.C. Rep. Serv. (West) 1608, 1980 U.S. Dist. LEXIS 13059, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aldeman-v-general-motors-acceptance-corp-in-re-tulsa-port-warehouse-co-oknd-1980.