College Park Business and Industrial Development Authority v. College Park Mob, LLC

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2024
DocketA23A1332
StatusPublished

This text of College Park Business and Industrial Development Authority v. College Park Mob, LLC (College Park Business and Industrial Development Authority v. College Park Mob, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
College Park Business and Industrial Development Authority v. College Park Mob, LLC, (Ga. Ct. App. 2024).

Opinion

FOURTH DIVISION DILLARD, P. J., RICKMAN and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 13, 2024

In the Court of Appeals of Georgia A23A1332. COLLEGE PARK BUSINESS AND INDUSTRIAL DEVELOPMENT AUTHORITY v. COLLEGE PARK MOB, LLC.

PIPKIN, Judge.

In this dispute involving a contract for the purchase of real property, the trial

court granted summary judgment to Appellee College Park MOB, LLC on their claim

for specific performance against Appellant College Park Business and Industrial

Development Authority (“Appellant” or “BIDA”); the trial court also granted

summary judgment to Appellee on Appellant’s counterclaims for breach of contract

and expenses of litigation. Appellant now challenges both rulings on appeal. While we

agree with Appellant that the trial court’s specific performance analysis was

incomplete and, thus, that summary judgment was improper on that claim, we affirm

the judgment in all other respects. 1. This appeal requires us to delve into a purchase agreement for the sale of land

and consider the application of two of its provisions, namely, a reconveyance provision

and a right-of-first-refusal provision. To do so, we turn to the record before us,

viewing it in a light most favorable to Appellant as the non-moving party.1 See, e.g.,

Latson v. Boaz, 278 Ga. 113, 113 (598 SE2d 485) (2004). Appellant BIDA is “a

constitutional development authority incorporated and chartered under Georgia law”

and “is authorized [to], among other things . . . sell property to promote development

within the City of College Park, Georgia.” In September 2020, Appellant was

approached by a real estate entity -- who was acting on behalf of a third party -- to

purchase several tracts of land, most of which were then-owned by the City of College

Park. Subsequently, in December 2020, Appellant entered into a “Real Property

Purchase and Sale Agreement” (“Original PSA”) with that third party whereby

Appellant agreed to acquire, where necessary, and sell four tracts of land (“the

1 For reasons that are not immediately clear, the record that was transmitted to this Court includes hundreds of additional documents filed after the summary judgment order was entered. As Appellee correctly points out, Appellant relies on this “extended” portion of the record in its brief. As we have explained before, we review only that portion of the record that was before of the trial court at the time of its decision. See Cornwell v. Kirwan, 270 Ga. App. 147, 151 (2) (606 SE2d 1) (2004). 2 Property”) and offer a right of first refusal on a fifth parcel (“the Additional

Property”).

As relevant to this appeal, Section 8 of the Original PSA includes various

“Reconveyance Rights,” all of which were “to be made part of the limited warranty

deed by which the Property is conveyed to the Purchaser, unless Seller receives a

Lender’s request to the contrary.” Subdivision (F) of Section 8 included the following

provision:

Notwithstanding anything else to the contrary contained herein, the City of College Park shall not issue building permits for the Project until Purchaser provides proof that it has secured a performance bond for the Project in form and amount satisfactory to Seller to secure the faithful performance of this Agreement. The parties agree that performance means the construction of the Project as negotiated and agreed to among the parties (see Exhibit “B”). The failure of the commencement of the entire project or the failure of completion, as set out within thirty (30) months shall be cause to involve the recapture and reconveyance of the property by the Seller.

(Emphasis supplied; hereinafter “Section 8 (F)”) At the time that the Original PSA

was executed, “Exhibit B” was, in effect, blank and would be supplemented at a later

date.

The parties to the contract agreed to slight changes to the Original PSA twice

in 2021, but the original version remained largely in force. Appellant says that, during

3 this time, the parties had extensive discussions about the right of first refusal on the

Additional Property; according to Appellant, it was made abundantly clear that the

City of College Park, not Appellant, owned the Additional Property and that the City

was unlikely to offer it for sale. According to the executive director of BIDA, a stipend

was offered to the City of College Park to relocate the office that was operating on the

Additional Property, but the City rejected the proposal. In October 2021, a site plan

was submitted for the Property showing that it was being developed for medical offices

and retail space; according to Appellant, this site plan became Exhibit B related to

Appellant’s Reconveyance Rights in Section 8 (F). In late December 2021, the original

third-party purchaser assigned its right to Appellee College Park MOB, LLC.

The Original PSA, as amended, set a closing date of January 9, 2022, but the

parties agreed that they could not close by that date. In an apparent attempt to avoid

any kind of default, the parties signed what they called a “reinstatement” agreement,

which would supplant the Original PSA rather than amend it further. Consistent with

this decision, the January 2022 PSA includes a merger clause, which provides that the

January 2022 PSA was “the sole and entire agreement of the Parties, supersedes all

prior written or oral communications relating the subject matter hereof.” The January

4 2022 PSA altered some of the original terms of the parties’ agreement. As relevant

here, the January 2022 PSA removed from Section 8 (F) any reference to Exhibit B,

which was the site plan ostensibly depicting medical offices and retail space. The

right-of-first-refusal provision was also amended to include the following language:

“Purchaser shall deliver to Seller a recordable Right of First Refusal Agreement for

review and approval at least three (3) business days prior to closing.”

In the days leading to closing, Appellee provided the necessary documents --

complete with the required signatures -- as well as all required funds. While Appellant

provided a limited warranty deed to the Property, the deed included language

restricting the development of the land to “the construction of a 27,000 to 40,000 sq.

ft. medical office building.” Appellee took issue with this language, asserting that

nothing in the January 2022 PSA permitted such restrictions; Appellant did not

remove the language. With respect to the Additional Property, Appellant offered only

a conditional right of first refusal, which was triggered in the event that Appellant

“should . . . ever acquire said property.” Appellee challenged the right of first refusal

offered by Appellant, too, but there was no resolution. Appellant did not appear for

closing and did not complete any closing documents; the sale did not close.

5 In a March 2022 complaint, Appellee alleged that Appellant breached the

January 2022 PSA by failing to complete and supply the necessary closing documents,

by failing to deliver the appropriate warranty deed, by failing to provide proof that they

had the authority to execute the PSA and convey title without the authority or consent

of a third party, and by failing to provide a valid right of first refusal. Appellee sought

various forms of relief including, as relevant here, specific performance.

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