McCraine v. Voyellesland Farms, Inc.

177 So. 3d 811, 15 La.App. 3 Cir. 396, 2015 La. App. LEXIS 2165, 2015 WL 6735399
CourtLouisiana Court of Appeal
DecidedNovember 4, 2015
DocketNo. 15-396
StatusPublished

This text of 177 So. 3d 811 (McCraine v. Voyellesland Farms, Inc.) 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
McCraine v. Voyellesland Farms, Inc., 177 So. 3d 811, 15 La.App. 3 Cir. 396, 2015 La. App. LEXIS 2165, 2015 WL 6735399 (La. Ct. App. 2015).

Opinion

THIBODEAUX, Chief Judge.

_JjIn this dispute over the terms of an agricultural lease for farming, plaintiff J.L. McCraine, III appeals the trial court’s judgment dismissing his petition for damages in tort, breach of contract, unjust enrichment, detrimental reliance, and specific performance resulting from his eviction from leased land owned by defendant Voyellesland Farms Inc. (Voyellesland). Voyellesland also seeks review of its Re-conventional Demand, seeking damages for various unpaid fees and expenses. In the absence of a signed lease for the years in question, and void of contract terms referencing fees and expenses owed to Defendant, the trial court dismissed the claims of both parties.

McCraine asserts that the trial court erred in finding that the 2006 lease was for a one year term rather than a five year term that began in 2004, and that he had no ownership rights to the crawfish remaining in the ponds in 2006 and to be harvested in 2007. We disagree and find that the trial court’s judgment was not manifestly erroneous in dismissing the demands of both McCraine and Voyellesland. For the following reasons, we affirm the judgment of the trial court.

I.

ISSUES

We must determine:

(1) whether the trial court erred in finding that the lease in effect in 2006 was a one year lease that terminated on December 31, 2006, rather than a five year lease that began in 2004;
[813]*813(2) whether the trial court erred in finding that the crawfish remaining in the ponds on December 31, 2006, were not a crop owned by McCraine; and
k(3) whether the trial court erred in dismissing Voyellesland’s claims for damages for unpaid rice storage and drying fees, fuel, off-loading, and rental expenses.

II.

FACTS AND PROCEDURAL HISTORY

This case concerns an agricultural lease for land between plaintiff J.L. McCraine, III and defendant Voyellesland Farms Inc., a company owned and operated by I.V. Jeansonne. It arises in the aftermath of a divorce settlement between Jeansonne and the plaintiff’s mother. In 2003, McCraine signed a one year agricultural lease with Voyellesland that ' granted McCraine rice and soybean farming rights, and, secondarily, “crawfishing rights” from January 1, 2003 through December 31, 2003. An identical one year lease was signed for the 2004 season.

In 2004, and prior to the expiration of his lease, McCraine contends that in accordance with an oral agreement between him and Jeansonne, McCraine made improvements to the land in exchange for the promise of a new five year lease which would extend through 2009. The extent of such improvements is disputed, and Jean-sonne denies the promise of a five year lease. Alternatively, individual one year leases were drafted for the 2005, 2006, and 2007 years but remained .unsigned. A five year lease was never drafted.

Following his eviction from the land in 2006, and before his 2007 crawfish harvest, McCraine filed suit for damages. Vo-yellesland filed a Reconventional Demand alleging McCraine’s debt for failure to pay fees for rice storage and drying, fuel expenses, off-loading expenses, and rental expenses. The trial court dismissed both claims. Thereafter, McCraine appealed and 1 ^Voyellesland filed an Answer to Plaintiffs appeal seeking review of the trial court’s denial of its Reconventional Demand.

III.

LAW AND DISCUSSION

The Duration of the Lease in Effect in 2006

Absent manifest error or unless it is clearly wrong, an appellate court may not set aside a trial court’s finding of fact. Stobart v. State, Through DOTD, 617 So.2d 880 (La.1993); Rosell v. ESCO, 549 So.2d 840 (La.1989). Accordingly, if the trial court’s findings were reasonably based upon the entire record and evidence, we must not reverse. Housley v. Cerise, 579 So.2d 973 (La.1991). “Where there is conflict in the testimony, reasonable evaluations of credibility and reasonable inferences of fact should not be disturbed upon review....” Id.

McCraine contends that the trial court erred in ruling that the 2006 lease was for a one year term, maintaining that a five year lease began in 2004 pursuant to an oral modification. We disagree. McCraine and Voyellesland both acknowledge the validity of individual one year land leases for the 2003 and 2004 years. They additionally acknowledge that individual leases were drafted for the 2005, 2006, and 2007 years, but remained unsigned.

The past conduct of the parties is also significant. There is no ambiguity in the parties’ intent to create year-to-year lease terms. The consecutive creation of one year leases in 2003 and 2004 reflects this intent. This intent is further demonstrat[814]*814ed in that despite the plaintiffs claim that the parties agreed to a five year lease in 2004, separate one year leases were instead drafted for the following three years. We conclude that if the parties had in fact agreed to the Rcreation of a five year lease term, it, rather than one year lease terms, would have been drafted in 2004. Although the 2005, 2006, and 2007 leases remained unsigned, the record testimony is bolstered by their mere presence. The parties’ intent is further apparent in the language of the signed leases, which provides that “no renewal or extension shall be effective unless made in writing and executed by the parties.”

The trial court also considered the testimony of McCraine and Voyellesland’s witnesses, and found Voyellesland’s witnesses regarding the length of the leases to be more credible. “When findings are based on determinations regarding the credibility of witnesses, the manifest error-clearly wrong standard demands great deference to the trier of fact’s findings_” Rosell, 549 So.2d at 844. In light of the evidence presented, the trial court reasonably determined that the parties did not agree to a five year oral modification of the lease.

Finally, we find that if the parties failed to agree to a lease term, they were bound to one year leases by operation of law. Louisiana Civil Code Article 2680 provides that “[i]f the parties have not agreed on the duration of the term ... [a]n agricultural lease shall be from year to year.” Because neither party drafted a five year lease nor signed the individual leases for the 2005, 2006, and 2007 years, we also find that by operation of law the lease terms were on a year-to-year basis.

Ownership of the 2007 Crawfish Harvest

In concluding that the agricultural lease was on a year-to-year basis, we also agree with the trial court’s finding that the agricultural lease expired on December 31, 2006. For that reason, we must also consider the ownership rights to the crawfish crop during the years in which McCraine leased the land and also the ^ownership rights to the crawfish remaining on the land once the lease terminated. This is a question of law to be reviewed by this court under the de novo standard of review. Land v. Vidrine, 10-1342 (La.3/15/11), 62 So.3d 36.

The crawfish farmed by McCraine are to be considered a crop and thus subject to his ownership during his tenancy on the land. This is supported not only by McCraine’s testimony, but also by the testimony of Dr. Huner, Jeffrey Sylvester, and Jared Sylvester, who each categorized crawfish as a crop at trial.

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Related

Stobart v. State Through DOTD
617 So. 2d 880 (Supreme Court of Louisiana, 1993)
Texas Gas Transmission Corporation v. Soileau
251 So. 2d 104 (Louisiana Court of Appeal, 1971)
Rosell v. Esco
549 So. 2d 840 (Supreme Court of Louisiana, 1989)
Housley v. Cerise
579 So. 2d 973 (Supreme Court of Louisiana, 1991)
Land v. Vidrine
62 So. 3d 36 (Supreme Court of Louisiana, 2011)
Manuel v. Texas Gas Transmission Corp.
153 So. 2d 157 (Louisiana Court of Appeal, 1963)
Lewis v. Klotz
39 La. Ann. 259 (Supreme Court of Louisiana, 1887)
Deville v. Couvillion
5 La. App. 519 (Louisiana Court of Appeal, 1926)

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Bluebook (online)
177 So. 3d 811, 15 La.App. 3 Cir. 396, 2015 La. App. LEXIS 2165, 2015 WL 6735399, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccraine-v-voyellesland-farms-inc-lactapp-2015.