Graftaire, LLC v. City of Shreveport

CourtLouisiana Court of Appeal
DecidedJuly 17, 2024
Docket55,741-CA
StatusPublished

This text of Graftaire, LLC v. City of Shreveport (Graftaire, LLC v. City of Shreveport) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Graftaire, LLC v. City of Shreveport, (La. Ct. App. 2024).

Opinion

Judgment rendered July 17, 2024. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,741-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

GRAFTAIRE, LLC Plaintiff-Appellee

versus

CITY OF SHREVEPORT Defendant-Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 638,359

Honorable Ramon Lafitte, Judge

MAYER, SMITH & ROBERTS, LLP Counsel for Appellant By: Deborah Shea Baukman

MARCUS E. EDWARDS Shreveport City Attorney

HARPER LAW FIRM Counsel for Appellee, By: Jerald R. Harper Graftaire, LLC Anne E. Wilkes Counsel for Intervenors/ Appellees, Experimental Aircraft Association, Shreveport Chapter 343 of La., Inc., Terry M. Sullivan, Mark Roberts and Randy A. Northcutt

Before THOMPSON, MARCOTTE, and ELLENDER, JJ. MARCOTTE, J.

This appeal arises from the First Judicial District Court, Parish of

Caddo, the Honorable Ramon Lafitte presiding. Defendant-Appellant, the

City of Shreveport (the “City”) appeals the trial court’s ruling granting a

preliminary injunction prohibiting the City from terminating or threatening

to terminate the leases of plaintiff-intervenor-appellees Mark Roberts

(“Roberts”), Randy A. Northcutt (“Northcutt”), Terry M. Sullivan

(“Sullivan”), and Experimental Aircraft Association, Shreveport Chapter

343 of LA, Inc. (the “EAA”) (herein collectively referred to as (“plaintiffs”

or “appellees”).

FACTS AND PROCEDURAL HISTORY

For many years, Shreveport’s downtown airport leased raw land to

tenants to allow them to build hangars thereon. The City historically used

standard form leases, which contained the following term:

If LESSEE, having been given permission to remove Improvements from the Leased Premises does not do so and does not leave the Leased Premises in a clean and appropriate condition within ninety (90) days following termination of the lease, LESSEE’s right to remove shall cease and at the option of LESSOR, the improvements shall become the property of LESSOR without any further action required of LESSOR, and LESSEE shall be deemed to have forfeited any ownership right in and to the Improvements and be deemed to have conveyed the Improvements to LESSOR.

Citing this improvement reversion clause in letters dated June

16, 2022, Oliver Jenkins (“Mr. Jenkins”), chairman of the Shreveport

Airport Authority (“SAA”) Board, informed plaintiffs that their leases

were expiring and that they had to remove their hangars from the premises within a contractual time period or the improvements would

revert to the City.

On July 14, 2022, the original plaintiff, Graftaire, L.L.C.

(“Graftaire”), filed a petition for declaratory judgment, preliminary

injunction and permanent injunction.1 In the petition and subsequent

motions for intervention, Graftaire argued that the City sought to

prematurely terminate the lease agreement and to take the lessees’ hangars

without compensation, in violation of the takings clause of the Louisiana

Constitution of 1974.

At the same time, Graftaire filed a motion for preliminary injunction.

In response, the City filed an answer setting forth affirmative defenses as

well as a reconventional petition to evict Graftaire. After significant motion

practice, the parties ultimately appeared before the trial court for a hearing

on the first preliminary injunction on August 17-18, 2022.

During that hearing, plaintiffs put on evidence through witness

testimony that the City was attempting to prematurely terminate their leases,

that the City was attempting to take their hangars without compensation, and

that the City had a long history of making prior assurances to lessees that it

would not enforce the provisions of the lease regarding termination. The

City also admitted that this was its practice, according to testimony from

Stacy Kuba (“Ms. Kuba”) (who, at the time of her testimony, was the City’s

Deputy Director of Airports) and Mr. Jenkins.

1 Appellees, Roberts, the EAA, Northcutt, and Sullivan, later intervened. Since Graftaire is no longer a lessee of the City, its claims are now moot.

2 On August 18, 2022, the trial court granted the first preliminary

injunction, finding that plaintiffs had a substantial likelihood of success on

the merits that the City was prematurely terminating the hangar owners’

leases. The trial court deferred ruling on the constitutional issues. At that

point, the parties agreed and advised that it would likely be necessary for the

trial court to address the constitutional issues at a later date in a second

preliminary injunction hearing, which was held on February 7-8, 2023.

Prior to the second preliminary injunction hearing, the parties

expressly agreed that the evidence and testimony adduced, introduced, and

admitted during the hearing on the first preliminary injunction would be

incorporated and admitted at the second hearing.

At the second preliminary injunction hearing, plaintiffs presented

three bases for an injunction: (1) constitutional waiver, that the lease

agreement did not constitute an appropriate, knowing, and voluntary waiver

of plaintiffs’ constitutional rights to compensation for a taking; (2)

Shreveport City Code of Ordinances Section 18-33, which requires City

Council approval for the SAA to acquire any immovable property, for which

the SAA had none; and, (3) detrimental reliance, that there were

representations made by SAA administration and board members assuring

plaintiffs that there would be no action taken at the conclusion of the lease

and that plaintiffs would merely be offered a new lease with the same terms

and conditions. The trial court, however, granted a motion in limine from

the City to exclude testimony based on detrimental reliance.

Mr. Jenkins testified at the second preliminary injunction hearing that,

in his opinion, Section 18-33 of the City of Shreveport Code of Ordinances

3 was only meant to apply to instances of expropriation and thus did not

prevent the City from lawfully asserting its rights under the improvement

reversion clauses in the leases.

Ms. Kuba testified at the second preliminary injunction hearing that

the improvement reversion provisions in the lease agreements were standard

and not negotiable. Ms. Kuba further testified that the lease language at

issue was vague and needed clarification, and that in 2019, the standard form

leases were modified to make them more clear about improvement reversion

at the conclusion of the lease.

George Carroll, President of the EAA, testified that the EAA was a

charitable organization which owned a hangar and had a lease at the

downtown airport. He testified that he never understood that the EAA was

giving up ownership of its hangar to the City without any compensation.

Northcutt, who owned a hangar and had a lease at the downtown

airport, also testified. He said that the new lease he was offered by the City

included provisions requiring him to make upgrades and improvements to

his hangar in addition to paying the City $20,000 for the first ten years of the

lease. In regards to his current lease with the SAA, Mr. Northcutt testified

that when he signed the lease, he never thought he would be forfeiting any

constitutional rights he had with respect to his property. He said it never

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Graftaire, LLC v. City of Shreveport, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graftaire-llc-v-city-of-shreveport-lactapp-2024.