Fitness International, Llc, V. National Retail Properties, Lp

CourtCourt of Appeals of Washington
DecidedFebruary 21, 2023
Docket84242-1
StatusPublished

This text of Fitness International, Llc, V. National Retail Properties, Lp (Fitness International, Llc, V. National Retail Properties, Lp) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fitness International, Llc, V. National Retail Properties, Lp, (Wash. Ct. App. 2023).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

FITNESS INTERNATIONAL, LLC, a California limited liability company, No. 84242-1-I

Appellant, DIVISION ONE

v. PUBLISHED OPINION

NATIONAL RETAIL PROPERTIES, LP, a Delaware limited liability company,

Respondent.

MANN, J. — On March 16, 2020, Governor Jay Inslee issued the first of several

public health orders directing all nonessential businesses, including gyms and fitness

centers, to immediately cease operating to prevent the spread of the 2019 novel

coronavirus (COVID-19). While the initial closure was lifted in August 2020, a second

closure occurred between November 2020 and January 2021. Fitness International,

LLC, operates an “LA Fitness” health and fitness club in Spanaway at a facility it leases

from National Retail Properties, LP (National Retail). As a result of the closures, Fitness

International sued National Retail for breach of lease and sought declaratory judgment

based on the equitable doctrines of frustration of purpose and impossibility or For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 84242-1-I/2

impracticability. Fitness International appeals the trial court’s order granting summary

judgment and dismissing its claims. We affirm.

I.

As of March 2020, Fitness International owned and operated over 700 large

health clubs in 27 states and the District of Columbia, including 28 in Washington.

Most of the health clubs operated under the trade name “LA Fitness.” Fitness

International has approximately five million active members. National Retail is a real

estate investment trust that owns commercial properties nationwide.

In July 2015, Fitness International brought in National Retail as a development

partner, and they entered into a series of agreements relating to the acquisition,

development, and leasing of a vacant 3.77 acre parcel in Spanaway, Washington

(premises). Together the contracts formed a “reverse build-to-suit” transaction. 1

Relevant here, under the development agreement, Fitness International agreed to

develop the premises for a health and fitness facility that Fitness International would

then lease from National Retail. Under a separate lease agreement, Fitness

International agreed to lease the premises from National Retail for an initial term of 19

years with 4 options to extend the term of the lease up to 40 years.

The lease describes the uses allowed on the premises. “Initial uses” are for the

“operation of a health club and fitness facility” which includes, “without limitation,” a long

list of activities such as personal training, lessons, group classes, weight and aerobic

training, youth instruction, and saunas. The lease also allows a long, nonexclusive list

1 The premises was initially owned by a third-party developer, Spanaway Village, L.P. Fitness

International purchased the property from the developer, and then, under the “assignment and assumption of contract” agreement assigned all of its rights and obligations to the purchase to National Retail.

-2- For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 84242-1-I/3

of “ancillary uses” that Fitness International can use the premises for, including uses

such as tanning services, cosmetic treatments, child care facilities, food and beverage

services, spa services, dry cleaning drop-off and pickup, car washing/detailing, shoe

repair, and nutritional supplement sales. The lease leaves it to Fitness International’s

business judgment to decide ancillary uses for the premises:

for such other use as Tenant may determine in Tenant’s reasonable business judgment, provided that such use: (i) is lawful; (ii) is in compliance with applicable environmental, zoning and land use laws and requirements; (iii) does not violate matters of record or restrictions affecting the Premises; (iv) does not conflict with any other agreement to which Landlord is bound, of which agreement Tenant has received written notice, where such conflict would materially adversely affect Landlord; (v) would not have a material adverse effect on the value of the Premises; and (vi) would not result in or give rise to any material environmental deterioration or degradation of the Premises.

The development agreement allocated some risk and excused some

performance for “Force Majeure Events.” The force majeure clause stated:

If either party is delayed or hindered in or prevented from the performance of any act required hereunder because of strikes, lockouts, inability to procure labor or materials, retraction by any governmental authority of the building permit, failure of power, restrictive laws, riots, insurrection, war, fire, inclement weather or other casualty or other reason of a similar or dissimilar nature beyond the reasonable control of the party delayed, financial inability excepted (each, a “Force Majeure Event”), the performance of such act shall be excused for the period of delay caused by Force Majeure Events.

The lease does not contain a similar force majeure clause.

On March 16, 2020, Governor Inslee issued the first of several public health

orders directing all nonessential businesses, including gyms and fitness centers, to

immediately cease operating to prevent the spread of the COVID-19 virus. On August

10, 2020, the state permitted indoor clubs and gyms in Pierce County to operate under

-3- For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 84242-1-I/4

restricted guidelines. Another COVID-19 closure period occurred from November 17,

2020 to January 10, 2021. During these closure periods it was illegal for Fitness

International to use the premises to operate a health club and fitness facility. In January

2021, the public health orders abated and Fitness International resumed operations.

National Retail requested full rental payments under the lease during the closure

periods.

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