DH Overmyer Co., Inc. v. Irving Trust Co.

60 B.R. 391, 1986 U.S. Dist. LEXIS 28099
CourtDistrict Court, S.D. New York
DecidedMarch 17, 1986
Docket83 Civ. 5692 (SWK)
StatusPublished
Cited by4 cases

This text of 60 B.R. 391 (DH Overmyer Co., Inc. v. Irving Trust Co.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DH Overmyer Co., Inc. v. Irving Trust Co., 60 B.R. 391, 1986 U.S. Dist. LEXIS 28099 (S.D.N.Y. 1986).

Opinion

MEMORANDUM OPINION AND ORDER

KRAM, District Judge.

FACTUAL BACKGROUND

Irving Trust Company (“Irving”) leased four floors in a commercial building located in Manhattan from Seymour B. Durst, Roy H. Durst, David M. Durst and Alma D. Askin for a 21-year term, ending in 1986. Pursuant to a sublease dated September 1, 1965, D.H. Overmyer Company, Inc. (“Ov-ermyer”), rented two of these floors from Irving for approximately fifteen years— from 1965 to 1980.

On November 16, 1973, Overmyer filed a bankruptcy petition under Chapter XI; on or about December 26, 1973, the bankruptcy court granted Overmyer’s application to reject and disaffirm its unexpired sublease with Irving. Irving then attempted to rer-ent the space vacated by Overmyer for $8.50 per square foot, which exceeded the $5.50 per square foot price which Over-myer had paid. Irving was unable to rer-ent the entire space and recouped only a portion of its damages. Irving subsequently filed a proof of claim for $650,272.99 (later amended to $476,043.93 at trial) for losses arising from Overmyer’s rejection of the lease.

Overmyer objected to Irving’s claim by Notice and Application dated November 24, 1976. On March 3, 1978, a trial of the objections was held before Bankruptcy Judge Roy Babitt. While this matter was sub judice, Bankruptcy Judge Joel Lew-ittes replaced Judge Babitt before the lat *393 ter had issued a decision. The parties agreed to allow Judge Lewittes to rule upon Irving’s claim without a further evi-dentiary hearing.

In his January 14, 1983 decision, Judge Lewittes ruled that Irving had not sustained actual damages as a result of Over-myer’s rejection of the unexpired lease agreement. The Court found that Irving failed to overcome the governing presumption that a landlord can rerent a premises at the same rate as is reserved under the lease. Thus, the Court ruled that the “survival clause” 1 contained in the sublease (which provided Irving with liquidated damages in the event that Overmyer breached the lease) should not be triggered to grant Irving its requested relief.

The bankruptcy court stated that the federal courts “uniformly follow” a rule for calculating damages in these situations. January 14, 1983 decision, at 12. This rule, established by the Supreme Court in City Bank Farmers Trust Co. v. Irving Trust Co., 299 U.S. 433, 57 S.Ct. 292, 81 L.Ed. 324 (1937), provides that damages for the breach of an unexpired lease in the bankruptcy context consist of “the difference between the present value of the rent reserved under the lease and the present fair rental value of the property for the remainder of the term, presumptively equal amounts.” January 14, 1983 decision, at 13. 2 The bankruptcy court stated that when applying this rule, a rebuttable presumption exists that the lessor can rerent the leased premises without incurring loss. Id. This presumption is rebutted if the landlord can show that despite “reasonable efforts,” he was unable to rerent at the lease amount. Id. at 27.

In reaching his decision, Judge Lewittes did not apply the damages formula established in Irving Trust Co., but initially looked to the survival clause created by the parties. 3 However, before applying the survival clause the Court adopted the presumption that a landlord can rerent at the lease amount and inquired as to whether Irving made reasonable efforts to rerent the premises. The Court added:

*394 While a state court would not require a landlord to make reasonable efforts to mitigate damages due under a survival clause, this Court must. And the reasonable efforts this Court requires should not differ depending upon whether a lease includes a survival clause or whether judicially determined measurements of rejection damages apply instead.

Id. at 27. Thus, the Court determined that the reasonableness inquiry was necessary regardless of whether the Court applied the damages formula used by the federal courts or the survival clause appearing in the lease.

After analyzing Irving’s efforts to rerent the premises, the Court concluded that Irving failed to rebut the presumption that a landlord can rerent an unexpired lease term at the lease amount. Id. The Court reached this determination because Irving sought to rerent the space vacated by Ov-ermyer at its fair market value, which exceeded the amount provided in the lease.

In reaching this decision, the Court rejected the New York rule that a landlord need not use reasonable efforts to rerent a premises once the lease has been terminated, since it would lead to an unreasonable result. Id. at 16. The Court explained that this rule gave Irving the potential of a double recovery: Irving could collect three years rent from the debtor in a bankruptcy proceeding and rerent the premises to a third party. Id. The Court determined that this rule conflicted with bankruptcy policy and thus should not be followed. Id. The Court concluded that Irving failed to sustain actual damages and thus, was not entitled to the damages provided for in the survival clause.

After issuing this decision, Judge Lew-ittes resigned. Pursuant to this decision, Bankruptcy Judge John J. Galgay expunged Irving’s claim in an order dated June 8, 1988. In the instant motion, Irving appeals this order.

ISSUES PRESENTED

Irving argues that the bankruptcy court erred in failing to award damages as provided for in the survival clause of the sublease. Secondly, Irving maintains that the bankruptcy court should have applied New York law, which does not require a landlord to mitigate damages in a commercial setting. 4

Overmyer contends, inter alia, that Irving simply failed to prove that it sustained actual damages as a consequence of Over-myer’s rejection of the sublease and that the Court properly applied the federally created law of rejection damages.

THE LAW

Section 353 of the Bankruptcy Act, 11 U.S.C. § 753 (repealed), 5 provides a limitation of damages for landlords’ claims based on rejected unexpired leases. Under this provision, a landlord can prove his claim for losses resulting from the rejection of an unexpired lease of real estate but may only recover

an amount not to exceed the rent, without acceleration, reserved by such lease for the three years next succeeding the date of the surrender of the premises to the landlord ... plus unpaid accrued rent, without acceleration, up to the date of surrender.

Although Section 353 provides a limitation on the amount of damages a landlord can recover, it fails to include a method of calculating these damages.

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

Related

In Re Merry-Go-Round Enterprises
241 B.R. 124 (D. Maryland, 1999)
In Re Andover Togs, Inc.
231 B.R. 521 (S.D. New York, 1999)
In Re Child World, Inc.
161 B.R. 349 (S.D. New York, 1993)
In Re J. Bildner & Sons, Inc.
106 B.R. 8 (D. Massachusetts, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
60 B.R. 391, 1986 U.S. Dist. LEXIS 28099, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dh-overmyer-co-inc-v-irving-trust-co-nysd-1986.