Myers v. East Ohio Gas Co.

364 N.E.2d 1369, 51 Ohio St. 2d 121, 5 Ohio Op. 3d 103, 58 Oil & Gas Rep. 341, 1977 Ohio LEXIS 445
CourtOhio Supreme Court
DecidedJuly 20, 1977
DocketNo. 76-1007
StatusPublished
Cited by34 cases

This text of 364 N.E.2d 1369 (Myers v. East Ohio Gas Co.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Myers v. East Ohio Gas Co., 364 N.E.2d 1369, 51 Ohio St. 2d 121, 5 Ohio Op. 3d 103, 58 Oil & Gas Rep. 341, 1977 Ohio LEXIS 445 (Ohio 1977).

Opinions

WxmiAM B. Brown, J.

The main issue presented by this cause is whether a “Supplemental Gas Storage Agreer ment” for a primary term, followed by a grant of uncertain [123]*123duration that conditions termination upon the occurrence of an event within the control of the “lessee,” gives rise to a tenancy at will once the primary term has expired.

• In the Rayl case, supra (46 Ohio App. 2d 167), the' Court of Appeals for Summit County held that a gas storage agreement, terminable after a ten-year primary period upon the failure of the “lessee” to produce, store or withdraw gas from underground storage areas became a tenancy at will once the primary term expired. The Rayl court reasoned (1) that the gas storage agreement was “simply a rental agreement for the use of the lessor’s land”; (2) that the'tenancy created by that agreement was not like those created in oil and gas drilling agreements because it was terminable at the will of the gas company and not “by contingency or operation of the law”;1 and (3) that the law in Ohio is that “a tenancy at the will of one party is also a tenancy at the will of the other,” and, therefore, that the gas storage agreement could be terminated at will by the landowners.2 (Rayl, at pages 172-173.)

[124]*124We are not persuaded by this reasoning. In the first place, it is by no . means certain whether the property interest or estate created by the gas storage agreement is a tenancy.”3 Assuming, arguendo, that the agreement does create a tenancy, however, we do not agree that it creates a tenancy at will.

The characteristics of a tenancy at will, whether it is created by express contract or by implication of law, are “uncertainty respecting duration and the right of either party to terminate it by proper notice * * 3 Thompson on Beal Property 33, Section 1020 (1959); Thompson v. Baxter (1909), 107 Minn. 122, 123, 119 N. W. 797; 1 Casner, American Law of Property, 229, Section 3.28 (1952); 1 Be-statement of Property, Section 20 (1936); 1 Bestatement of Property 2d, Section 1.6 (1976). At common law, because a fee simple could not be granted without livery of seisin, a lease purporting, without livery of seisin, to grant an estate otherwise the equivalent of a fee was ineffective to convey the estate granted. Therefore, courts treated an estate of uncertain duration, terminable at the will of the grantee, as if it were also terminable at the will of the grantor. From this treatment of estates at will arose the legal inference, which has outlasted livery of seisin, that a lease terminable at the will of one party is terminable at the will of both. Effinger v. Lewis (1859), 32 Pa. 367, 369; Lindlay v. Raydure (E. D. Ky. 1917), 239 F. 928, 942 ; 2 Summers, The Law of Oil & Gas, 136-137, Section 235 [125]*125(1959); 1 Casner, American Law of Property, supra, at page 231, Section 3.30. The implications of this rule aré best expressed by Casner, supra, at pages 231 and 232:

“Coke after commenting that a lease at will must in law be at the will of both parties, stated * * * that a lease to hold at the will of the lessee ‘must also be at the will of the lessor.’ ”

“Taken literally,” Coke’s proposition “would seem to state that all leases for life or in fee become leases at will if the lessee has power to terminate the lease at any time, and this literal interpretation has been used in some cases. Still, it is clear that one can create a life estate or a fee on limitation or subject to a condition, and it would seem immaterial that the event on which the estate is conditioned or limited is within the control of the owner of the estate.”

Livery of seisin has, of course, long been a mere legal memory, and the rule that a lease at the will of one party is at the will of both has no other apparent usefulness. In addition to having outlived its usefulness and to having possibly barred otherwise valid grants of life estates or fees, the rule may also frustrate the intent of the parties to the lease. It is a legal commonplace that courts, in deciding the rights of parties under a written agreement, including a lease, should give effect to the unambiguously expressed intent of the parties. See Hallock v. Kintzler (1943), 142 Ohio St. 287; Stahl v. Van Vleek (1895), 53 Ohio St. 136; Bell v. Panhandle Eastern Pipeline Co. (S. D. Ind. 1976), P. Supp. ; Charles Ilfeld Co. v. Taylor (1964), 156 Colo. 204, 397 P. 2d 748. The doctrine urged by the Bayl court does not promote the intention of the parties. See Thompson v. Baxter, supra, at page 123. Instead, it may thwart their intention by creating a lease terminable at the will of both parties even in those agreements which clearly and unambiguously provide for termination at the will of only one party. Thus, it was only after the court in Effinger v. Lewis, supra, rejected the rule that it was able to say, at page 370:

“There is nothing, therefore, to prevent us from giv[126]*126ing effect to this contract according to the intention of the parties. If they meant to create an estate that-'should endure so long.as the grantee, his heirs and-assigns,, should desire to keep it at the rent agreed upon, then such is its character; and this silences all the minor objections brought to bear on the title.”

Despite the fact that it has outlived the purpose for which it was created and that it may thwart the intent of the parties and unnecessarily block the grant of otherwise valid estates, the doctrine that a lease at the will of one party is a lease at the will of both has been adopted by a majority of American jurisdictions and has been referred to as the prevailing law by a number of commentators. Annotation, 137 A. L. R. 362, 367; 33 Ohio Jurisprudence 2d 604, Landlord and Tenant, Section 79;' 51C Corpus Juris Secundum 475, Landlord and Tenant, Section 167. Ohio, however, has not adopted the rule,4 and we decline to do so.at this time. Instead, in keeping with what we perceive to be a better approach to the rule than its total acceptance or rejection and in recognition of the .validity of. the rule-at common law, which may have been relied upon in particular cases, we elect to treat the.doctrine as a presumption. Sincé a “presumption cannot arise where the very terms of the * * * [agreement] are squarely to the contrary,? ’ Adams Express Co. v. Bechwith (1919), 100 Ohio. St. 348, 357, those leases which clearly and unambiguously terminate at.the will of only one party are to be controlled by their express terms. However, those leases which, do not clearly state whether they are terminable at the will of one or , both [127]*127parties will be presumed, in keeping with the majority rule, to be terminable at the will of both parties. Our treatment of the rule as a rebuttable presumption is in keeping with the judicial practice of giving effect to the intent of the parties where possible (Stahl v. Van Vleck, supra), with our prior treatment of perpetual leases (see Hallock v. Kintzler, supra,

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Bluebook (online)
364 N.E.2d 1369, 51 Ohio St. 2d 121, 5 Ohio Op. 3d 103, 58 Oil & Gas Rep. 341, 1977 Ohio LEXIS 445, Counsel Stack Legal Research, https://law.counselstack.com/opinion/myers-v-east-ohio-gas-co-ohio-1977.