L & M Real Estate v. Consolidated Rail Corp.

2024 Pa. Super. 291, 328 A.3d 1068
CourtSuperior Court of Pennsylvania
DecidedDecember 9, 2024
Docket2925 EDA 2023
StatusPublished
Cited by1 cases

This text of 2024 Pa. Super. 291 (L & M Real Estate v. Consolidated Rail Corp.) 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
L & M Real Estate v. Consolidated Rail Corp., 2024 Pa. Super. 291, 328 A.3d 1068 (Pa. Ct. App. 2024).

Opinion

J-A14010-24

2024 PA Super 291

L & M REAL ESTATE DEVELOPMENTS, : IN THE SUPERIOR COURT OF LLC : PENNSYLVANIA : Appellant : : : v. : : : No. 2925 EDA 2023 CONSOLIDATED RAIL CORPORATION :

Appeal from the Order Entered October 23, 2023 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 201201840

BEFORE: LAZARUS, P.J., STABILE, J., and LANE, J.

OPINION BY LAZARUS, P.J.: FILED DECEMBER 9, 2024

L&M Real Estate Developments, LLC (L&M), appeals from the order,

entered in the Court of Common Pleas of Philadelphia County, granting

summary judgment in favor of Appellee Consolidated Rail Corporation

(Conrail). After careful review, we affirm.

L&M is a limited liability company that has its principal place of business

in Philadelphia. On December 17, 2020, L&M entered into an Agreement of

Sale (Agreement) with Conrail for 1.98 acres of commercial property, located

at 2750R Aramingo Avenue, in Philadelphia (Propery), for a purchase price of

$2.4 million. The Property is zoned industrial and was restricted, by deed,

from being used residentially. However, section 6(b) of the parties’

Agreement permitted a purchaser to remediate the Property to a residential

standard so that it could be used for residential purposes. J-A14010-24

In order for the zoning on the Property to change from industrial to

residential, the City of Philadelphia would have to approve a use variance. In

a 2018 letter of intent to purchase the Property, L&M indicated that it intended

to seek zoning approval to allow residential use of the Property, with the intent

to construct townhomes as part of a large multi-family housing complex. In

a subsequent letter of intent, dated July 2019, L&M issued a final plan to

increase the number of townhouses on the Property.

Pursuant to section 2 of the Agreement, closing was to occur “on or

before the earlier of 35 days following [Zoning Board of Adjustment] approval

or 7/15/20, or such other time and place as shall be mutually agreed upon,

excepting as hereinafter provided[.]” An addendum to the Agreement further

provided, in relevant part:

Purchaser shall use due diligence to obtain subdivision approval in an expedited manner, including if necessary, the filing for special exceptions, variances, or appeal. In the event that subdivision approval cannot be obtained within ninety (90) days of the date of this Agreement, for any reason other than a failure on the part of the Purchaser, this Agreement shall thereupon be rendered null and all monies paid on deposit shall be returned to Purchaser without interest, and there shall be no further obligations between the parties hereto. Purchaser shall copy Conrail on all correspondence and submissions, applications, and other information with any governmental entity arising out of or related to the application for subdivision.

* * *

The Closing shall take place not later than ten (10) business days from receipt of final Zoning approval as provided in Section 2 (Closing) of the Agreement or at a specific time and place to be mutually agreed upon by the parties hereto.

-2- J-A14010-24

Addendum: Survey & Subdivision Requirements, 12/17/19, at 6 (emphasis

added).

Due to administrative delays caused by the COVID-19 Pandemic, L&M

requested an extension of time to secure variance use approval and permits.

The parties executed an amendment (First Amendment) on June 16, 2020,

which extended the subdivision approval date until November 15, 2020. The

First Amendment also provided that “if prior to November 15, 2020, [L&M]

requests, in writing, a further extension of time to obtain its subdivision

approval, Conrail shall not unreasonably decline a further thirty (30) day

extension to December 15, 2020.” See Conrail Letter, 6/16/20, at 2.

Pursuant to the First Amendment, no further extensions beyond December

15, 2020, “shall be permitted without the express written consent of Conrail.”

Id. When L&M was unsuccessful in obtaining the necessary permits and

approvals by the extended date, Conrail gave L&M a one-month extension to

December 15, 2020. Finally, Conrail agreed to an additional two-week

extension, requiring L&M to secure the necessary approvals by 5:00 PM on

December 30, 2020.

Conrail refused to approve another amendment, requested by L&M, to

further extend the closing date, citing the following reasons:

Conrail was not fully kept in the loop as to zoning and subdivision approvals, applications[,] and related correspondence, so new information has recently come to light regarding the scope of the planned residential project. Conrail is unable to grant any further extensions. The Agreement of Sale, as amended by the two letter agreements, will automatically terminate on 12/30/2020[,]

-3- J-A14010-24

pursuant to its terms. As no escrow deposits were made, the parties do not need to coordinate any deposit returns.

Email from Dana Janquitto to Dade J. Thornton, 12/29/20. Later that day,

Conrail sent another email to L&M stating:

Conrail has elected not to cure encumbrances on the Title Report pursuant to Section 3 of the [Agreement]. Additionally, it’s our understanding that all permits and approvals required for subdivision approval have not yet been received, so[,] among other things, any conveyance of the [P]roperty tomorrow would constitute an illegal subdivision pursuant to the Pennsylvania Municipalities Planning Code, and the applicable section of the Philadelphia ordinance. Thus, the contract also terminates pursuant to Section 14.

Email from Dana Janquitto to Dade J. Thornton, Larry McKnight, & Mo Rushdy,

12/29/20. Conrail gave L&M written notice of its election to terminate the

Agreement pursuant to sections 3 and 14 of the Agreement. See Agreement,

12/17/19, at ¶ 3 (Title); id. at § 14 (Violation of Law).

On March 18, 2021, L&M filed a breach of contract action1 against

Conrail, alleging it breached the Agreement. The complaint sought specific

performance, monetary damages in excess of $6.3 million, and included a

claim for unjust enrichment. Conrail filed preliminary objections to the

complaint. On May 25, 2021, L&M filed an amended complaint, no longer

including a claim for unjust enrichment, alleging that Conrail acted in bad faith

by “manufactur[ing] reasons to pull out of its deal with L&M in order to try to

____________________________________________

1 L&M first commenced litigation by filing a writ of summons. Later, L&M filed lis pendens against the property, in contravention of section 7(b) of the Agreement. On November 10, 2023, L&M filed a praecipe to remove the lis pendens on the Property.

-4- J-A14010-24

obtain a higher price for the Property.” Amended Complaint, 5/25/21, at ¶ 4.

L&M also alleged that Conrail “unilaterally and without cause [] terminated the

[A]greement on the literal eve of the scheduled closing, December 29, 2020.”

Id. at ¶ 5.

Conrail filed preliminary objections to the amended complaint asserting:

(1) there was no breach of the Agreement under the facts as pled; (2) even

if there were a breach, L&M’s damages were limited to return of the deposit,

of which there was none; and (3) section 7(b) of the Agreement was a

limitation of liability clause which, as a matter of law, did not permit recovery

on the basis of bad faith. See Preliminary Objections, 6/15/21, at ¶¶ 23-25.

On November 5, 2021, the trial court overruled Conrail’s preliminary

objections.

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Bluebook (online)
2024 Pa. Super. 291, 328 A.3d 1068, Counsel Stack Legal Research, https://law.counselstack.com/opinion/l-m-real-estate-v-consolidated-rail-corp-pasuperct-2024.