Lassman v. DeVoe

United States Bankruptcy Court, D. Massachusetts·Decided March 19, 2021·No. 18-01192·Unknown

Opinion

UNITED STATES BANKRUPTCY COURT DISTRICT OF MASSACHUSETTS EASTERN DIVISION

In re Chapter 7 NOUH AD B. B ECHARA and Case No. 18-13601-FJB M ONA M. B ECH ARA,

Debtors

DONALD R. LASSMAN, Chapter 7 Trustee, Adversary Proceeding No. 18-1192 Plaintiff

v.

ROBERT DeVOE, Individually and as Trustee of the R&M REALTY TRUST,

Defendants

MEMORANDUM OF DECISION

I. Overview In this adversary proceeding, the Chapter 7 Trustee Donald Lassman (the “Trustee”) of the estate of Nouhad and Mona Bechara (the “Debtors”) seeks damages from Robert DeVoe, both individually and as the Trustee of the R&M Realty Trust (the “Defendants”). The trial in this case was held on February 9, 10 and 11, 2021. Following the close of evidence, the Defendants each filed a motion for judgment on partial findings pursuant to Fed. R. Civ. P. 52(c), made applicable by Fed. R. Bankr. P. 7052 (the “52(c) motions”). The complaint in this case alleges that the Defendants are liable to the estate for breach of contract, the business tort of interference in advantageous relations, and violation of Mass. Gen. Laws ch. 93A (unfair or deceptive acts or practices in commerce.) By the time the trial ended, the Trustee reduced his claims to the interference tort and ch. 93A violation. Moreover, although the complaint was entirely premised on the Trustee’s allegation that the Defendants interfered with the Debtors’

right under a commercial lease to assign the lease, at the end of the trial the Trustee stated that his case, as tried, was for interference with the Debtors’ efforts to sell their convenience store business, which sale required a new lease between prospective buyers and the Defendants. The Trustee has sought to amend his pleadings to reflect this change. The Trustee seeks a second amendment of the pleadings to include a count for unjust enrichment that was not in

his original complaint. The Trustee relies on Fed. R. Civ. P. 15(b) arguing that the court should allow an amendment to the complaint to reflect the case that was actually tried. The Defendants object, arguing that they never consented to the amendment of the pleadings and would be unduly prejudiced by such an amendment. The Trustee has conceded that unless the court allows the requested amendment, judgment should enter for the Defendants. Given the gravity of the request, after the trial, the court requested briefs on the issue of the amendment

of the complaint either during or after the trial. II. Rule 15(b) and the Arguments of the Parties Federal Rule of Civil Procedure 15(b), which is applicable to this proceeding by virtue of Fed. R. Bankr. P. 7015, addresses amendments of the pleadings during and after trial: Rule 15(b)(1). Based on an Objection at Trial. If, at trial, a party objects that evidence is not within the issues raised in the pleadings, the court may permit the pleadings to be amended. The court should freely permit an amendment when doing so will aid in presenting the merits and the objecting party fails to satisfy the court that the evidence would prejudice that party's action or defense on the merits. The court may grant a continuance to enable the objecting party to meet the evidence. Rule 15(b)(2). For Issues Tried by Consent. When an issue not raised by the pleadings is tried by the parties’ express or implied consent, it must be treated in all respects as if raised in the pleadings. A party may move—at any time, even after judgment—to amend the pleadings to conform them to the evidence and to raise an unpleaded issue. But failure to amend does not affect the result of the trial of that issue. When the parties submitted their briefs, it became apparent to the court that they were like “ships passing in the night.” The Trustee argues that the Defendants consented to the amendment of the complaint to address interference with the Debtors’ right to sell the business by refusing to agree to a new lease. The Defendants argue that they certainly did not consent and that they would be prejudiced by the requested amendment. More important, because the Trustee has not plainly stated whether he is relying on Rule 15(b)(1) or (2), I must infer from his post trial brief that he is relying on Rule 15(b)(2). Indeed, his brief does not address prejudice to the Defendants. III. Analysis As noted, there are two procedures under which the court can allow an amendment to the pleadings during or after the trial. First, if a party seeks to offer evidence at the trial that is not raised in the pleadings and the opposing party objects, the court should allow the amendment unless it would unduly prejudice the opposing party. Second, when an issue not raised in the pleadings is actually tried, whether objected to or not, the court may allow the amendment upon a finding that the opposing party either actually or impliedly consented to the

amendment. In either case, the court must ensure that the due process rights of the opposing party are protected. The party seeking the amendment must demonstrate that it clearly indicated that it was trying a theory outside the pleadings. In his opening statement, the Trustee clarified that he was no longer relying on the Defendants’ refusal to allow an assignment of the lease because he conceded that no assignment was ever requested. In fact, for that reason, he agreed to dismiss his breach of contract claim.

While the Trustee was not clear in his opening statement that he was instead relying on the Defendants’ alleged refusal to offer a new lease as the operative fact in support of his interference tort and statutory claims, Defendants’ counsel were clear in their opening statements that they were planning to prove that the Debtors required the Defendants to offer a new lease to a prospective buyer. In fact, that was an important feature of their defense.

Defendants stressed that they were never legally required to offer a new lease to any prospective tenant, certainly not on the same terms as the lease to the Debtors. Logically then, the Defendants were not caught unprepared to address the issue of the new lease. Finally, I also note that more than a year before trial, Trustee’s counsel stated at a pretrial conference that the Trustee was relying on a refusal to permit an “assignment or a new lease” as his theory. Therefore, I find that the Defendants impliedly consented to the Trustee’s amendment to the

pleadings to include interference with the Debtors’ efforts to sell their convenience store business under Rule 15(b)(2). I note that it is by far best practice for a plaintiff to move for an amendment of the complaint in advance of the trial rather than argue, as here, that the court should deem the pleadings amended after the trial. But the philosophy underlying modern pleading practice is to have disputes adjudicated on their merits, not on a formalistic and narrow reading of the pleadings. In making this ruling, I am guided by those principles.

As to the Trustee’s request that the complaint be amended to include a count for unjust enrichment, that request is denied. His theory appears to be that the Defendants, who now operate a convenience store at the location in question, are unfairly benefiting from that operation.

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