In re Group V Partnership

73 B.R. 342, 1987 U.S. Dist. LEXIS 3059
CourtDistrict Court, N.D. Illinois
DecidedApril 9, 1987
DocketNo. 86 C 5395
StatusPublished

This text of 73 B.R. 342 (In re Group V Partnership) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Group V Partnership, 73 B.R. 342, 1987 U.S. Dist. LEXIS 3059 (N.D. Ill. 1987).

Opinion

MEMORANDUM AND ORDER

MORAN, District Judge.

Group V Partnership (“Group V”) is an Illinois limited partnership engaged in the business of owning single family homes for investment purposes and renting those homes to the public. Its original general partners were Douglas H. Scott, Richard E. Scott, Douglas W. Scott and IRE, Inc. After Group V and its four original general partners filed separate petitions for relief under Chapter 11 of the Bankruptcy Code, 11 U.S.C. § 1101 et seq., some of Group V’s limited partners amended Group V’s Articles of Limited Partnership to substitute Randall S. Jaros for the original general partners. The original general partners appeal from identical orders entered in all five Chapter 11 cases confirming Jaros as Group V’s new sole general partner. They do not dispute that Group V’s Articles of Limited Partnership allow limited partners to enact such an amendment. Instead, they argue that the orders must be reversed because the limited partners failed to follow proper procedures. The court disagrees, and the orders are affirmed.

Beginning on December 14, 1985, and continuing through January 8,1986, limited partners holding over 83% of the partnership units signed the amendment. On January 24, 1986, copies of the amendment were delivered to the partners who had not signed, including the original general partners. Four more limited partners consented in writing to the amendment, bringing the number of partnership units consenting [343]*343to the amendment to approximately 89% of the total. By its terms, the amendment became effective on January 24,1986, after all of the partners had been served with a copy executed by partners holding at least 75% of the outstanding partnership units.

On February 6,1986, Jaros filed a motion before the bankruptcy judge to confirm his substitution as the new sole general partner and to compel the former general partners to turn over Group V’s partnership records. On March 4, 1986, the original general partners filed separate motions for rule to show cause why Jaros and certain limited partners of Group V should not be held in contempt for expelling the general partners in violation of the automatic stay provision of the Bankruptcy Code. 11 U.S.C. § 362. After holding an evidentiary hearing the bankruptcy judge granted the motion by Jaros and denied the motion by Group V’s original general partners on June 3, 1986. The original general partners filed this appeal after the bankruptcy judge denied their motion to alter the order on June 13, 1986.

The original general partners first argue that the bankruptcy judge improperly confirmed Jaros because Group V’s Articles of Limited Partnership were not properly amended. They contend that section 17B of Group V’s Articles of Limited Partnership 1 requires limited partners holding 10% or more of the partnership units to request in writing that the general partners cause a vote to be taken on matters covered in section 17A, including a change in Group V’s general partners. The general partners’ responsibilities in responding to such a request, such as scheduling the meeting and notifying the other partners, are specifically set forth in section 17E. The original general partners argue that this is the exclusive procedure for amending Group V’s Articles, and it was not followed here. Instead, the proposed amendment was circulated among Group V’s limited partners, most of whom signed it and waived notice of any meeting. Rather than requesting the general partners to cause a vote to be taken, the limited partners presented them with a fait accompli: an amendment already approved by limited partners owning more than enough partnership units for the amendment to take effect. Alternatively, the original general partners argue that under section 17D they were entitled to prior notice of the proposed amendments, but they were given no notice at all until the day the amendment was effective.

The limited partners interpret section 17 rather differently. They observe that nothing in section 17 makes the meeting procedures mandatory or exclusive. In their view, limited partners holding 10% or more of the partnership units can force the general partners to convene a meeting and cause a vote to be taken on a proposed amendment, but if the limited partners can secure approval of the proposed amendment from limited partners holding 75% or more of the partnership units without holding a meeting, such a meeting need not be held. They further contend that giving prior notice of a proposed amendment to general partners is unnecessary under section 17D since that section refers only to an amendment, not a proposed amendment. According to the limited partners, all section 17D requires is that all partners be notified of an amendment before the amendment takes effect, and they complied with that requirement. In support of their interpretation of section 17 the limited partners rely heavily on section 17F, which requires that an expelled partner be notified in writing of his expulsion. They contend that section 17F would be superfluous if the general partners controlled the entire process leading to the expulsion.

We agree with the bankruptcy judge that section 17 is ambiguous. The original general partners offered no extrinsic evidence to support their interpretation of section 17, and the limited partners’ offer to introduce evidence of prior amendments adopted without a meeting was rejected by. the bankruptcy judge. Based on the language of section 17 alone, the limited partners’ interpretation is persuasive. The original general partners’ interpretation of section [344]*34417 is not implausible, but they were responsible for drafting Group V’s Articles of Limited Partnership, so any ambiguities must be construed against them. See, e.g., Lippo v. Mobil Oil Corp., 776 F.2d 706, 714-15 & n. 15 (7th Cir.1985); KFK Corp. v. American Continental Homes, Inc., 71 Ill.App.3d 304, 27 Ill.Dec. 420, 425, 389 N.E.2d 232, 237 (2d Dist.1979). We believe the bankruptcy judge properly interpreted section 17 in holding that Group V’s limited partners complied with the Articles of Limited Partnership when they adopted the amendment expelling the original general partners.

The original general partners next argue that their post-petition expulsion violated 11 U.S.C. § 362(a)(3), which automatically stays

any act to obtain possession of property of the estate or of property from the estate or to exercise control over property of the estate.

According to the original general partners, the amendment is void because it was executed before the automatic stay was lifted.

Whether the automatic stay provision applies to the action taken here is not entirely clear. See In re Unit, Inc., 45 B.R. 425, 427 (Bankr.S.D.Ohio 1984) (suggesting, but not holding, that removal of general partners violated the automatic stay); In re John J. Gilece, Jr., 1 B.R. 762, 765 (Bankr.E.D.Pa.1980) (holding that debt- or’s termination as corporation’s president did not violate the automatic stay);

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Related

Turner v. Lee (In Re Minton Group, Inc.)
46 B.R. 222 (S.D. New York, 1985)
Matter of Unit, Inc.
45 B.R. 425 (S.D. Ohio, 1984)
KFK CORP. v. American Continental Homes, Inc.
389 N.E.2d 232 (Appellate Court of Illinois, 1979)

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Bluebook (online)
73 B.R. 342, 1987 U.S. Dist. LEXIS 3059, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-group-v-partnership-ilnd-1987.