Old Navy, LLC v. South Lakeview Plaza I, LLC

CourtMissouri Court of Appeals
DecidedJuly 18, 2023
DocketED111214
StatusPublished

This text of Old Navy, LLC v. South Lakeview Plaza I, LLC (Old Navy, LLC v. South Lakeview Plaza I, LLC) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Old Navy, LLC v. South Lakeview Plaza I, LLC, (Mo. Ct. App. 2023).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

OLD NAVY, LLC, ) No. ED111214 ) Appellant, ) Appeal from the Circuit Court of ) St. Louis County vs. ) ) Honorable Brian H. May SOUTH LAKEVIEW PLAZA I, LLC, ) ) Respondent. ) Filed: July 18, 2023

Introduction Old Navy, LLC (“Appellant”) appeals the judgment of the Circuit Court of St. Louis

County denying its motion for partial summary judgment and granting summary judgment for

South Lakeview Plaza I, LLC (“Respondent”). Appellant raises four points on appeal. In Point I,

Appellant argues the trial court erred in granting Respondent’s motion for summary judgment

because the uncontroverted facts demonstrate Appellant’s leased property was separately assessed

for real estate tax purposes within the meaning of the lease. In Point II, Appellant argues the trial

court erred in granting Respondent’s motion for summary judgment based on waiver because this

issue was not properly raised by Respondent and is not supported by the record. In Point III,

Appellant argues the trial court erred in denying Appellant’s motion for partial summary judgment

because Respondent applied the wrong formula and overcharged Appellant for property taxes

under the lease. In Point IV, Appellant alternatively argues the trial court erred in denying Appellant’s motion for partial summary judgment because Respondent breached the lease by

failing to use its best efforts to separately assess the leased property for real estate tax purposes.

Because Appellant stipulated the new tax parcel was created for the purposes of obtaining

financing, we deny Point I. Because Appellant’s awareness of Respondent’s billing practices

presents a genuine issue of material fact, we grant Point II. Because our holdings addressing

Respondent’s motions for summary judgment preclude summary judgment for Appellant, we

decline to address Points III and IV, which concern Appellant’s motions for summary judgment.

We reverse and remand in part, and affirm in part.

Factual and Procedural History In 1981, South Lakeview Plaza, LLC leased commercial property in a new shopping center

to Service Merchandise Company, Inc. The lease, amended in 1987, obligates the tenant to pay a

portion of the shopping center’s property taxes. The lease contemplates two methods to apportion

real estate taxes among tenants: creating a separate tax parcel for real estate tax purposes

representing Appellant’s leased property, or assessing tenants’ real estate tax responsibilities under

a proportional share based on their square footage as a share of the entire shopping center.

Specifically, the lease required the landlord “to use its best efforts to have the demised premises

separately assessed for general ad valorem real estate tax purposes.” “In the event the demised

premises are not separately assessed,” the lease provided Appellant’s obligation would be based

on the proportional formula as a share of the entire shopping center.

After leasing the commercial space, South Lakeview Plaza, LLC completed construction

of the shopping center. To obtain a construction loan, South Lakeview Plaza, LLC was required

by its lender to divide the original tax parcel embracing the shopping center into two tax parcels.

2 The original tax parcel was divided into two parcels, creating a “new tax parcel” including

Appellant’s leased property, plus parking lots and a stormwater pond.1 The other tax parcel

includes the remaining buildings and property in the shopping center.

In 1999, Service Merchandise Company assigned its interest in the lease to GPS Real

Estate, Inc., which assigned its interest in the lease to Appellant.2 Appellant has occupied the

property since 1999 and has been billed its portion of the real estate taxes under the proportional

formula for the entire shopping center described in the lease. In 2011, South Lakeview Plaza, LLC

transferred its interest in the lease to Respondent. In 2012, Appellant audited Respondent’s tax

invoices and concluded it was overcharged for its share of real estate taxes. Respondent refused

Appellant’s demands for a refund.

On October 5, 2016, Appellant filed a petition which alleged breach of contract and

requested a declaratory judgment. At Appellant’s request, the trial court dismissed Appellant’s

petition without prejudice on April 20, 2020. On March 25, 2021, Appellant re-filed its petition,

alleging its tax obligation under the lease should have been calculated using the new tax parcel

Respondent created, not the proportional formula provided in the lease. Appellant pled since it

“acquired its interest in the Lease, the real estate ad valorem taxes [Appellant] paid far exceeded

the real estate ad valorem taxes assessed on the Separate Parcel.” The petition included three

counts. In Count I, Appellant alleged a breach of contract because Respondent charged Appellant

for property taxes under the proportional formula, even though the new tax parcel existed, resulting

1 It is undisputed a new tax parcel was created, which included Appellant’s leased property. The question in Point I is whether, within the meaning of the lease, this new parcel was a “separate tax parcel” created for real estate tax purposes. 2 In 2004, Old Navy, Inc., became Old Navy, LLC. We refer to both as Appellant.

3 in damages exceeding $605,682.16 from 2005 through 2021.3 In Count II, Appellant alternatively

alleged breach of contract because Respondent failed to use its best efforts to have the leased

property separately assessed for real estate tax purposes. In Count III, Appellant sought a

declaration of its tax obligation for the remainder of the lease. Appellant also requested attorneys’

fees. Respondent filed an answer on May 6, 2021, listing eleven assertions as “affirmative

defenses,” including “waiver, estoppel, laches, and unclean hands.”

The parties submitted stipulated facts on July 12, 2022. One stipulation provided “[i]n

1981, [the new tax parcel] was created for the purposes of obtaining a loan to construct the building

leased by Plaintiff (‘the Property’) in the South Lakeview Plaza Shopping Center (‘Shopping

Center’).” Emphasis added. On July 22, 2022, the parties filed cross-motions for summary

judgment. Appellant’s motion for partial summary judgment asserted a right to judgment “for

breach of a written commercial real estate lease for the payment of real estate ad valorem taxes on

leased real property.” Respondent’s motion for summary judgment alleged it was never required

to and was never asked to have the leased property separately assessed. Respondent alleged the

leased property was not separately assessed within the meaning of the lease because the new tax

parcel includes more than the leased property and was not created for tax assessment purposes, but

merely to accommodate a requirement of Respondent’s lender. On August 19, 2022, Respondent

filed a response to Appellant’s motion for partial summary judgment, challenging Appellant’s

interpretation of the lease and alleging Appellant waived its breach of contract claim. The trial

court held a hearing on the cross-motions on September 20, 2022.

3 At the summary judgment hearing, Appellant’s counsel argued, under the applicable statute of limitations, “we can go back ten years from our initial claim in 2016.” Appellant’s counsel agreed this meant conduct before 2006 was time barred.

4 At the hearing, the trial court observed the invoices from Respondent were not in evidence.

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Old Navy, LLC v. South Lakeview Plaza I, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/old-navy-llc-v-south-lakeview-plaza-i-llc-moctapp-2023.