Ex parte MUSA Properties, LLC PETITION FOR WRIT OF MANDAMUS: CIVIL

CourtSupreme Court of Alabama
DecidedMay 19, 2023
Docket2022-1061
StatusPublished

This text of Ex parte MUSA Properties, LLC PETITION FOR WRIT OF MANDAMUS: CIVIL (Ex parte MUSA Properties, LLC PETITION FOR WRIT OF MANDAMUS: CIVIL) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte MUSA Properties, LLC PETITION FOR WRIT OF MANDAMUS: CIVIL, (Ala. 2023).

Opinion

Rel: May 19, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2022-2023

_________________________

SC-2022-1061 _________________________

Ex parte MUSA Properties, LLC

PETITION FOR WRIT OF MANDAMUS

(In re: R.K. Allen Oil Co., Inc.

v.

MUSA Properties, LLC)

(Calhoun Circuit Court, CV-22-900138)

MENDHEIM, Justice. SC-2022-1061

MUSA Properties, LLC ("MUSA"), and R.K. Allen Oil Co., Inc.

("Allen Oil"), entered into a real-estate sales contract ("the sales

contract") in which MUSA agreed to purchase from Allen Oil a gasoline

service station and convenience store ("the property"). The terms of the

sales contract were not fulfilled, and the property was not transferred to

MUSA. Allen Oil filed a lawsuit in the Calhoun Circuit Court ("the

circuit court") against MUSA, alleging various causes of action based on

the sales contract; MUSA filed various counterclaims in response. MUSA

also filed in the Calhoun Probate Court ("the probate court") a notice of

lis pendens describing the property. In an interlocutory order, the circuit

court later determined that MUSA did not have a right to or interest in

the property, and, upon the motion of Allen Oil, the circuit court entered

an order expunging the lis pendens notice. MUSA now petitions this

Court for a writ of mandamus directing the circuit court to vacate its

order expunging the lis pendens notice. We grant the petition and issue

the writ.

Facts and Procedural History

Pursuant to the terms of the sales contract, MUSA agreed to

purchase the property from Allen Oil for $1,250,000 and to close on the

2 SC-2022-1061

sale on May 31, 2021; $50,000 of the purchase price was to be deposited

with the closing attorney as earnest money upon execution of the sales

contract, with the remainder of the purchase price due upon closing. The

sales contract includes the following relevant provisions:

"[MUSA] shall be responsible for obtaining a title examination, survey of the property and purchasing title insurance, if desired. The cost of survey shall be paid by [MUSA]. If there are objections to title, environmental problems or defects in the improvements same will be communicated to [Allen Oil] promptly upon discovery. [Allen Oil] shall have at least thirty (30) days to cure said defects, but no more than sixty (60) days. The terms of this agreement shall be extended, if necessary, to accommodate this period of correction. This contract is contingent upon a satisfactory survey, environmental inspection and building inspection. In the event title defects or other problems cannot be cured, all earnest money shall be refunded to [MUSA] and this agreement shall become null and void. [MUSA] shall have the right to access the property to inspect it, but such inspection shall not change the purchase price.

"….

" This contract is contingent upon the following:

"1. [MUSA's] satisfaction with the results of a title examination and survey.

"2. [MUSA's] satisfaction with the results of any and all environmental inspections including but not limited to geological surveys, groundwater sampling, Phase I and Phase II environmental site assessments, etc.

"…. 3 SC-2022-1061

"In the event [MUSA] fails to carry out and to perform the terms of this agreement, any funds paid by [MUSA] to [Allen Oil] shall be forfeited as liquidated damages at the option of [Allen Oil] (provided [Allen Oil] agrees to the cancellation of this contract). In the event [Allen Oil] fails to carry out and to perform the terms of this agreement or fails to cure any title defects within a reasonable time, [MUSA] may avail itself of one of the following remedies: (1) [MUSA] will receive a refund of earnest money plus reimbursement for any sums expended by [MUSA] in conjunction with this transaction including but not limited to expenses for title examination, attorney's fees, appraisal, credit reports, survey, environmental studies, etc. Upon payment by [Allen Oil] of such expenses, the contract will become void; or (2) [MUSA] may elect to proceed with specific performance."

The parties also entered into a lease agreement "in order to allow [MUSA]

to take possession of the [property], operate the business located thereon,

and to otherwise prepare for the purchase of [the property]."

Subsequently, MUSA hired Karst Environmental to conduct a

"Phase II Environmental Site Assessment" of the property "to determine

whether the historical operation of the underground storage tanks

(gasoline and diesel) on the … property has adversely impacted the soil

and groundwater onsite." Karst Environmental conducted its

assessment on April 21, 2021, and produced a report on April 30, 2021,

summarizing the findings of its assessment ("the report"). The report

noted that "[t]here is one previous petroleum incident reported for [the 4 SC-2022-1061

property] in the regulatory agency database. That incident, UST96-11-

05, was resolved with a No Further Action (NFA) in April, 1995. The

report stated, in pertinent part, as follows (there are some terms and

abbreviations used in the report that are not defined by the report):

"The findings of this Phase II Environmental Site Assessment conclude that, 1) BTEX, MTBE, and Naphthalene concentrations in the soils exceeded the [Alabama Department of Environmental Management ('ADEM')] Initial Screening Limits, 2) BTEX, MTBE, and Naphthalene concentrations in the groundwater exceeded the ADEM Initial Screening Limit, 3) No liquid phase hydrocarbons (LPHs) were identified in either the soils or groundwater, and 4) if current compliance is maintained, the facility is eligible for participation through the [Alabama Tank Trust Fund] (in the event of a future petroleum release).

"The findings of this investigation should be discussed with … Allen Oil …. The release should be reported to the ADEM in a timely manner by forwarding this report to the ADEM Corrective Action Unit for review. The ADEM office in Montgomery, Alabama will determine whether further investigation will be required under the Alabama Tank Trust Fund …."

On May 4, 2021, the report was submitted to the Alabama

Department of Environmental Management ("ADEM") for review. After

reviewing the report, ADEM sent a letter to Allen Oil on May 11, 2021,

stating that,

"[b]ased on the previous release incident UST96-11-05 and the submitted report, [ADEM] has determined that no further 5 SC-2022-1061

investigative or corrective actions will be required for [the property] at this time. [ADEM] is not making a determination as to contamination which may or may not exist at [the property] and will review any additional information that may warrant further consideration should it become available."

(Emphasis in original.)

After receiving the report and ADEM's May 11, 2021, letter,

MUSA's trial attorney, Drew Senter, and Allen Oil's trial attorney,

Charles Gaines, communicated through emails and letters concerning

the sales contract and whether to proceed with the sale of the property.

On May 21, 2021, Senter sent Gaines the following email:

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Ex parte MUSA Properties, LLC PETITION FOR WRIT OF MANDAMUS: CIVIL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-musa-properties-llc-petition-for-writ-of-mandamus-civil-ala-2023.