Fraport Pittsburgh v. Allegheny County Airport

2023 Pa. Super. 77, 296 A.3d 9
CourtSuperior Court of Pennsylvania
DecidedMay 9, 2023
Docket974 WDA 2022
StatusPublished
Cited by13 cases

This text of 2023 Pa. Super. 77 (Fraport Pittsburgh v. Allegheny County Airport) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fraport Pittsburgh v. Allegheny County Airport, 2023 Pa. Super. 77, 296 A.3d 9 (Pa. Ct. App. 2023).

Opinion

J-A08032-23

2023 PA Super 77

FRAPORT PITTSBURGH, INC.; : IN THE SUPERIOR COURT OF FORMERLY KNOWN AS AIRMALL : PENNSYLVANIA PITTSBURGH, INC. : : Appellant : : : v. : : No. 974 WDA 2022 : ALLEGHENY COUNTY AIRPORT : AUTHORITY :

Appeal from the Order Entered August 17, 2022 In the Court of Common Pleas of Allegheny County Civil Division at No(s): GD-22-007444

BEFORE: STABILE, J., SULLIVAN, J., and PELLEGRINI, J.*

OPINION BY PELLEGRINI, J.: FILED: MAY 9, 2023

Fraport Pittsburgh Inc., f/n/a Airmall Pittsburgh, Inc. (Fraport)1 appeals

the order entered in the Court of Common Pleas of Allegheny County (trial

court) denying its motion for a preliminary injunction to enjoin the Allegheny

County Airport Authority (ACAA) from evicting it from leased premises and

otherwise interfering with its contractual rights under a Master Lease

____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1Fraport is a wholly-owned subsidiary of Fraport USA, which has contracts and leases at various airports in the United States. Fraport USA’s corporate parent is Fraport AG, a German company. (See N.T. Hearing, 7/01/22, at 30, 32). J-A08032-23

Agreement between the parties set to expire in December 2029 (Master

Lease).2 On appeal, Fraport challenges the trial court’s determination that it

failed to meet the standards necessary to obtain a preliminary injunction

because it could not show irreparable harm. We reverse and remand for

further proceedings.3

I.

The trial court aptly set forth the relevant facts and procedural history

of this case as follows:

This case arises out of a lease agreement between the Defendant, Allegheny County Airport Authority (‘ACAA’), and Plaintiff, Fraport Pittsburgh Inc. (‘Fraport’) at the Pittsburgh International Airport (‘the Airport’). The ACAA is a municipal authority of Allegheny County, which owns and operates the ____________________________________________

2 The complaint includes counts for Breach of Contract (Counts I-III), Breach

of Duty of Good Faith and Fair Dealing, Conversion, Intentional Interference with Existing and Prospective Economic Advantages, and Declaratory Judgment.

3 This interlocutory order denying injunctive relief is immediately appealable

as of right pursuant to Pa.R.A.P. 311(a)(4). Although ACAA maintains that transfer of this case to the Commonwealth Court is warranted because it is a “Commonwealth entity,” and the underlying substantive issues in this case lend themselves to the Commonwealth Court’s expertise, we disagree. (See ACAA’s Brief, at 3; citing 42 Pa.C.S. § 762(a)(1), (4)). While Section 762 of the Judicial Code provides for the Commonwealth Court’s exclusive appellate jurisdiction over civil cases “by the Commonwealth government,” municipal and other local authorities such as ACAA are specifically excluded from the definition of “Commonwealth government.” See 42 Pa.C.S. § 102 (prescribing Definitions for purposes of Judicial Code). Regarding ACAA’s claim that the underlying substantive issues in this case lend themselves to the Commonwealth’s expertise, we find that transfer is unnecessary given that the parties’ dispute centers on breach of their commercial lease agreement, the examination of which is within our purview.

-2- J-A08032-23

Airport. Fraport is a business engaged in the operations and management of retail and concessions at the Airport. Fraport Pittsburgh is a subsidiary of Fraport USA and, as a business entity, exists solely for the performance of its obligations under its lease agreement with the ACAA. No other entity leases the Airport’s commercial space from the ACAA, and Fraport serves no other airport.

The Fourth Amended and Restated Master Lease, Development and Concession Agreement (the ‘Lease’ or ‘Master Lease’), which grants an exclusive lease in the Airport’s commercial space to Fraport, was originally signed in 1991 between the ACAA and Fraport’s predecessor. The current lease term, which was renewed on December 27, 2012, runs until December 31, 2029. The Lease places Fraport in the role of the Airport’s Master Concessionaire and Lessee, in charge of subletting the Airport’s commercial spaces to restaurants, retail businesses, and other concessions. Among Fraport’s duties as Master Concessionaire are identifying and entering into subleases with commercial subtenants, managing logistics of the commercial spaces, collecting rent, and ensuring subtenant compliance with safety guidelines and regulations. The Lease requires Fraport to inspect subtenants ‘daily’ for compliance issues and to ensure that the subtenant is properly stocked, staffed, and operating. Although the Lease does not expressly impose a security duty upon Fraport, responsibility generally for the safety and security of the Airport is shared broadly among Fraport, the Transportation Security Administration (‘TSA’), the ACAA, the Allegheny County Police, and other Airport personnel. The Lease also requires Fraport to pay rent to the ACAA each month, based upon rent revenue received from subtenants during that month in the prior year, but this amount may be adjusted upon agreement of the parties. Fraport also retains a portion of the rent collected as part of its revenue.

Section 12 of the Lease provides for the procedures whereby the ACAA may terminate the Lease before expiration of the term. The ACAA can terminate the Lease if it notifies Fraport in writing of an Event of Default, which Event goes uncured for five days. An Event of Default is itself established upon the ACAA’s written notification to Fraport of a breach of the Lease agreement. If a breach is left uncured for more than thirty days it becomes an Event of Default. The current dispute between the parties concerns whether and to what extent Fraport may have breached

-3- J-A08032-23

its duties under the Lease, whether Fraport successfully cured any alleged breach, and whether the ACAA followed the proper procedures in notifying Fraport of alleged breaches and ripening those alleged breaches into Events of Default before terminating the Lease.

In the summer of 2021, the ACAA approached Michael Mullaney, the newly-appointed CEO of Fraport’s parent, Fraport USA, to discuss the possibility of prematurely terminating the Lease pursuant to a mutually agreeable arrangement. Namely, the ACAA offered to buy Fraport out of the remainder of the lease term for $5 million. Although Mr. Mullaney rejected the offer, he indicated Fraport USA’s willingness to negotiate a higher price. The ACAA, on the other hand, indicated it was not willing to negotiate further. Prior to these events, the relationship between the ACAA and Fraport was, to all appearances, cordial and successful. Nevertheless, after Fraport’s refusal, the ACAA began to find issues in the parties’ arrangement.

From September of 2021 through June of 2022, the ACAA attempted to identify, in writing, several Events of Default of the Lease agreement by Fraport. Among the Events of alleged Default were Fraport’s failure to conduct ‘daily’ inspections, the insufficiency of those inspections, the unilateral reduction in rent paid by Fraport during the height of the COVID-19 pandemic, the relaxation of certain safety regulations regarding access badges, and the failure to report and/or cure security risks of varying types in subtenant locations. Despite Fraport’s attempts to cure those alleged Events of Default, the ACAA continued to find new ones. This back-and-forth ultimately culminated in the ACAA summarily, and without prior notice, terminating the Lease and removing Fraport from the Airport premises on the morning of June 15, 2022.

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Fraport Pittsburgh v. Allegheny County Airport
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Bluebook (online)
2023 Pa. Super. 77, 296 A.3d 9, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fraport-pittsburgh-v-allegheny-county-airport-pasuperct-2023.