Great American Insurance Company v. 1914 Commerce Leasing

CourtCourt of Appeals of Washington
DecidedJune 7, 2022
Docket37959-1
StatusUnpublished

This text of Great American Insurance Company v. 1914 Commerce Leasing (Great American Insurance Company v. 1914 Commerce Leasing) 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
Great American Insurance Company v. 1914 Commerce Leasing, (Wash. Ct. App. 2022).

Opinion

FILED JUNE 7, 2022 In the Office of the Clerk of Court WA State Court of Appeals Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

GREAT AMERICAN INSURANCE ) No. 37959-1-III COMPANY, a foreign corporation, ) ) Respondent, ) ) v. ) ) 1914 COMMERCE LEASING, LLC, a ) Texas limited liability company; IRA C. ) WADDEY, JR. & ANN M. WADDEY, ) husband and wife; HIGH AND CHERRY ) LLC, an Ohio limited liability company; ) HOME SAVINGS BANK aka FIRST ) UNPUBLISHED OPINION FEDERAL BANK OF THE MIDWEST, ) an Ohio corporation; LINCOLN SQUARE ) ASSOCIATES 1766 LLC, a Delaware ) limited liability company; UDG 11th & ) BURNSIDE, LLC, an Oregon limited ) liability company; DRI/MAPLE 20th ) Street Station, LLC, a Delaware limited ) liability company; BCA Partners, LLC, an ) Indiana limited liability company; and ) ) ) No. 37959-1-III Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC

BARRY M. DAVIDSON, solely in his ) capacity as General Receiver of STAY ) ALFRED, INC., a Delaware corporation, ) fka ALFREDS AWAY, LLC, a ) Washington limited liability company, ) ) Defendants, ) ) TSO CHATTANOOGA ) DEVELOPMENT, LP, Georgia limited ) partnership, ) ) Petitioner. )

PENNELL, J. — TSO Chattanooga Development, LP seeks review of adverse

superior court orders denying its motion to dismiss for lack of personal jurisdiction and

enjoining litigation in the state of Tennessee. We reverse.

FACTS

TSO Chattanooga is a limited partnership, formed under Georgia law, owning

mixed commercial/residential property in Chattanooga, Tennessee. In April 2019, TSO

Chattanooga leased its property to a short-term rental startup, Stay Alfred, Inc. Stay

Alfred is a Delaware corporation, with its principal place of business in Spokane County,

Washington. The two parties entered into a commercial lease agreement (the Lease) and

Stay Alfred agreed to make monthly rental payments pursuant to the terms and conditions

of the Lease.

2 No. 37959-1-III Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC

Two aspects of the Lease are pertinent to our review. First, the Lease had a force

majeure1 clause that read:

If either party hereto shall be delayed or hindered in, or prevented from, the performance of any act required under this Lease by reason of strikes, walk outs, labor troubles, inability to procure materials, failure of power, weather, restrictive governmental laws or regulations, riots, insurrection, terrorism, war or other reason of like nature not the fault of the party delayed in performing work or doing as required under the terms of this Lease, then performance of such act or obligation shall be excused for the period of the delay and the period for cure or performance of any such act shall be extended for a period equivalent to the period of such delay. The provisions of this Section shall not excuse Tenant [Stay Alfred] from prompt payment of rent or any other monetary obligation under this Lease.

Clerks Papers, Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC, No. 37877-2-III (CP)

at 850-51. Second, the Lease contained a “governing law/jurisdiction” clause that read:

All rights and remedies of Landlord under this Lease shall be cumulative, and none shall exclude any other rights or remedies allowed by law. All the terms hereof shall be construed according to the laws of the State of Tennessee. Any action to enforce this Lease must be filed in the state or federal courts in Hamilton County, Tennessee, where the Premises is located.

1 Force Majeure is French for a superior force. In American law it is defined as “[a]n event or effect that can be neither anticipated nor controlled; esp., an unexpected event that prevents someone from doing or completing something that he or she had agreed or officially planned to do. The term includes both acts of nature (e.g., floods and hurricanes) and acts of people (e.g., riots, strikes, and wars).” Bryan A. Garner, BLACK’S LAW DICTIONARY (11th ed. 2019).

3 No. 37959-1-III Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC

Id. at 850.

Great American Insurance Company issued a lease guaranty bond (the Bond) on

behalf of Stay Alfred with respect to the Lease. The Bond provided that Great American

was bound to TSO Chattanooga for the sum of two months’ unpaid rent under the Lease,

not to exceed $187,500.00. The Bond also contained a force majeure clause. However,

the wording of the Bond’s force majeure clause differed from that in the Lease:

If said Principal [Stay Alfred] fails to make the monthly Base Rent payment(s) required in the Agreement due to a Force Majeure event, then said Surety [Great American] is not liable for any payment(s) then due subsequent to and arising, directly or indirectly, from the Force Majeure event.

CP at 871.

In April 2018, Stay Alfred and Great American entered into an indemnity

agreement relating to the issuance of the Bond. Stay Alfred also deposited the sum of

$803,029 with Great American as collateral for the TSO Chattanooga Bond and other

similar lease agreement bonds pertaining to other properties. According to the indemnity

agreement, Great American must return any portion of Stay Alfred’s cash deposit that is

not consumed by losses or expenses incurred by Great American in connection with the

Bond claims.

4 No. 37959-1-III Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC

In April and May of 2020, Stay Alfred failed to make its monthly rental payment to

TSO Chattanooga as required by the Lease. Stay Alfred’s default was purportedly related

to the COVID-19 pandemic. The amount of unpaid rent totaled $159,468. On May 18,

2020, TSO Chattanooga made a claim against the Bond for the unpaid rent due under the

Lease. Great American refused payment.

On May 26, 2020, Stay Alfred petitioned in Spokane County Superior Court for

appointment of a general receiver and executed an assignment for the benefit of creditors

pursuant to Washington’s receivership statute, chapter 7.60 RCW.

On June 8, 2020, TSO Chattanooga filed a proof of claim in Stay Alfred’s

receivership case in Spokane County Superior Court. TSO Chattanooga demanded all

money owed on the Lease, totaling $4,378,566 as of May 26, 2020. CP 439. The proof of

claim specified it was not a waiver or release of any claim of lack of venue or jurisdiction.

On June 23, 2020, Great American filed an adjunct complaint for declaratory

judgment in Spokane County Superior Court against TSO Chattanooga and a number of

similarly situated companies having rental relationships with Stay Alfred. Great American

asked the superior court to determine whether the Bond’s force majeure clause excused

its performance and liability under the Bond. Great American did not identify any

5 No. 37959-1-III Great Am. Ins. Co. v. 1914 Commerce Leasing, LLC

additional bases for avoiding liability. Great American requested the superior court enter

a declaratory judgment finding it was not liable to TSO Chattanooga under the Bond.

On July 21, 2020, TSO Chattanooga filed suit against Great American in Hamilton

County, Tennessee, seeking enforcement of the Bond and recovery of the amounts due

under the Bond. Great American successfully removed the Tennessee suit to federal

court.

On September 1, 2020, Great American filed a motion in Spokane County to

enjoin TSO Chattanooga from pursuing its lawsuit against Great American in Tennessee

until the receivership court rendered a final disposition and ruling on the declaratory

judgment action. Soon after, TSO Chattanooga contested personal jurisdiction and filed

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

Related

International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
Hanson v. Denckla
357 U.S. 235 (Supreme Court, 1958)
Goodyear Dunlop Tires Operations, S. A. v. Brown
131 S. Ct. 2846 (Supreme Court, 2011)
Kysar v. Lambert
887 P.2d 431 (Court of Appeals of Washington, 1995)
DeHeer v. Seattle Post-Intelligencer
372 P.2d 193 (Washington Supreme Court, 1962)
In Re the Marriage of Steele
957 P.2d 247 (Court of Appeals of Washington, 1998)
Shute v. Carnival Cruise Lines
783 P.2d 78 (Washington Supreme Court, 1989)
Daimler AG v. Bauman
134 S. Ct. 746 (Supreme Court, 2014)
Walden v. Fiore
134 S. Ct. 1115 (Supreme Court, 2014)
Ford Motor Co. v. Montana Eighth Judicial Dist.
592 U.S. 351 (Supreme Court, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Great American Insurance Company v. 1914 Commerce Leasing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-american-insurance-company-v-1914-commerce-leasing-washctapp-2022.