Patten/Jenkins BR Popeyes, L.L.C. v. SRG Baton Rouge II, LLC

CourtLouisiana Court of Appeal
DecidedJune 16, 2020
Docket2019CA1160
StatusUnknown

This text of Patten/Jenkins BR Popeyes, L.L.C. v. SRG Baton Rouge II, LLC (Patten/Jenkins BR Popeyes, L.L.C. v. SRG Baton Rouge II, LLC) 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
Patten/Jenkins BR Popeyes, L.L.C. v. SRG Baton Rouge II, LLC, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2019 CA 1160

PATTEN/ JENKINS BR POPEYES, L.L.C.

VERSUS

SRG BATON ROUGE II, L.L.C.

C JUN 16 2020 JUDGMENT RENDERED:

Appealed from the Nineteenth Judicial District Court In and for the Parish of East Baton Rouge • State of Louisiana Docket Number 681458 • Section 21 • Division D

The Honorable Janice Clark, Judge Presiding

Geoffrey D. Westmoreland ATTORNEY FOR APPELLANT Shreveport, Louisiana PLAINTIFF— Patten/ Jenkins BR Popeyes, L.L. C.

Jimmy Roy Faircloth, Jr. ATTORNEYS FOR APPELLEE Charles S. Weems, III DEFENDANT— SRG Baton Rouge B. Gene Taylor, III II, L.L. C. Alexandria, Louisiana

BEFORE: MCCLENDON, WELCH, AND HOLDRIDGE, JJ.

0 NO I j 1 4 loh (Afs w pt0A s T, < WELCH, J.

In this lessor -lessee dispute, Patten/ Jenkins BR Popeyes, L.L.C.

Patten/ Jenkins") seeks review of the trial court' s judgment sustaining a

declinatory exception raising the objection of lis pendens filed by SRG Baton

Rouge II, L.L. C. (" SRG"), which dismissed Patten/Jenkins' s claims against SRG.

For the following reasons, we affirm.

FACTUAL AND PROCEDURAL HISTORY

Pursuant to an assignment and assumption of a lease agreement, SRG leased

the immovable property located at 2137 Staring Lane, Baton Rouge, Louisiana,

from Patten/ Jenkins on March 8, 1999 in order to operate a Popeye' s restaurant on

the leased premises. The March 8, 1999 lease was for a twenty-year term— from

March 8, 1999, to March 8, 2019. 1 On April 1, 2019, Patten/ Jenkins initiated

3 eviction proceedings2 following the termination of the lease . Patten/ Jenkins

alleged that although section 28 of the lease contained an option to extend

provision, SRG failed to properly exercise the option to extend the lease beyond its

termination date. Therefore, Patten/Jenkins sought judgment in its favor ordering

SRG to vacate the leased premises immediately and deliver possession thereof to

Patten/ Jenkins, as well as reasonable attorney' s fees as provided for by the lease.

SRG answered the rule for eviction and filed an affirmative defense and a

declinatory exception raising the objection of lis pendens. In its objection of lis

pendens, SRG argued that it previously filed a petition for declaratory judgment,

specific performance, reformation, and damages against Patten/ Jenkins on

1 On September 30, 2013, SRG assumed the March 8, 1999 lease between FFCA Acquisitions Corporation, as original lessor ( Patten/ Jenkins' s predecessor -in -interest), and Sailormen, Inc., as original lessee ( SRG' s predecessor -in -interest).

2 See Docket Number 681458, Section 21, Division D, Nineteenth Judicial District Court (" 19th JDC"), Parish of East Baton Rouge, State of Louisiana.

3 Patten/ Jenkins alleged the lease terminated on March 8, 2019. In its answer, however, SRG stated that based on an estoppel certificate executed by Patten/ Jenkins when the lease was assigned and assumed by SRG, the termination date of the lease became March 31, 2019.

2 February 7, 2019, seeking declaratory relief and specific performance regarding

the enforcement of its exercised option to purchase the leased premises and

specifically for the continuation of occupancy by SRG during such reasonable time

as was required to complete the valuation and acquisition protocol as set forth in

the lease.' SRG further alleged that in its pending lawsuit, Patten/Jenkins filed an

answer and reconventional demand, alleging that SRG continued to occupy the

leased premises despite the expiration of the lease and prayed for judgment in its

favor against SRG. SRG argued that the two pending suits involved the same

parties in the same capacities and arose out of the same transaction and occurrence,

namely, SRG' s right to continue in occupancy under the lease. SRG averred that a

final judgment in its first -filed suit and on Patten/ Jenkins' s reconventional demand

would be res judicata in Patten/ Jenkins' s second -filed suit. SRG contended that

Patten/ Jenkins' s rule for eviction should therefore be dismissed.

In answering the rule for eviction, SRG admitted the existence of the lease

with Patten/ Jenkins and admitted that it did not exercise the option to extend the

lease as provided for in section 28; however, SRG averred that it instead exercised

the option to purchase the leased premises as provided for in section 23 of the lease

by timely sending the required option to purchase written notice to Patten/ Jenkins

on December 13, 2018, within the ninety -day period preceding the termination of

the lease. SRG further contended that section 23 of the lease allowed the closing

of the purchase to extend past the termination date of the lease and allowed the

lessee to remain in occupancy during the purchase closure process. Accordingly,

SRG pled as an affirmative defense its continued right of occupancy under the

lease.

Patten/ Jenkins opposed SRG' s objection of lis pendens. Following a

hearing, the trial court sustained SRG' s objection of lis pendens and dismissed 4 See Docket Number 679391, Section 27, Division J, 19th JDC, Parish of East Baton Rouge, State of Louisiana.

3 Patten/ Jenkins' s rule for eviction in a judgment signed on June 27, 2019.

Patten/ Jenkins now appeals.

LAW

The objection of lis pendens is raised by a declinatory exception. La. C. C. P.

art. 925. On the trial of the declinatory exception, evidence may be introduced to

support or controvert any objection pleaded when the grounds thereof do not

appear from the petition, the citation, or return thereon. La. C. C. P. art. 930. The

trial court has broad discretion in making evidentiary rulings, and its decision will

not be overturned absent an abuse of that discretion. Emery v. Owens -Corp.,

2000- 2144 ( La. App. 1St Cir. 11/ 9/ 01), 813 So. 2d 441, 448, writ denied, 2002-

0635 ( La. 5/ 10/ 02), 815 So. 2d 842. Error may not be predicated upon a ruling that

excludes evidence unless a substantial right of the party is affected and the

substance of the evidence is made known to the court by counsel. La. C. E. art.

103( A)(2).

Louisiana Code of Civil Procedure article 531 codifies the doctrine of lis

pendens:

When two or more suits are pending in a Louisiana court or courts on the same transaction or occurrence, between the same parties in the same capacities, the defendant may have all but the first suit dismissed by excepting thereto as provided in Article 925. When the defendant does not so except, the plaintiff may continue the prosecution of any of the suits, but the first final judgment rendered shall be conclusive of all.

The doctrine of lis pendens prevents a plaintiff from litigating a second suit

when the suits involve the same transaction or occurrence between the same parties

in the same capacities. For lis pendens to apply, La. C. C. P. art. 531 requires that:

1) two or more suits are pending in a Louisiana court or courts; 2) on the same

transaction or occurrence, which is determined on a case- by-case basis; and 3)

between the same parties in the same capacities. The test established to determine

0 if an objection of lis pendens should be sustained is the same as that for res

judicata, thus, an objection of lis pendens should be sustained if a final judgment

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Patten/Jenkins BR Popeyes, L.L.C. v. SRG Baton Rouge II, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pattenjenkins-br-popeyes-llc-v-srg-baton-rouge-ii-llc-lactapp-2020.