Putnam High Yield Municipal Trust v. First City Texas

862 F. Supp. 146, 1994 U.S. Dist. LEXIS 12359, 1994 WL 477234
CourtDistrict Court, S.D. Texas
DecidedAugust 19, 1994
DocketCiv. A. No. H-93-413
StatusPublished

This text of 862 F. Supp. 146 (Putnam High Yield Municipal Trust v. First City Texas) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Putnam High Yield Municipal Trust v. First City Texas, 862 F. Supp. 146, 1994 U.S. Dist. LEXIS 12359, 1994 WL 477234 (S.D. Tex. 1994).

Opinion

Opinion on Partial Summary Judgment

HUGHES, District Judge.

1. Introduction.

Bondholders bring a breach of trust action against the bank that held funds in trust for the completion of a specific airlines project and against a contractor on another airline project that has been paid with those funds. Because the bank breached the trust agreement, the bondholders will be granted a judgment on liability.

2. Background.

Continental desired to construct a new flight kitchen at Houston’s Intercontinental Airport. The funds necessary to construct the flight kitchen were obtained through the issuance of $19,600,000 of tax exempt bonds by the Harris County Industrial Development Corporation. The plaintiffs purchased the bonds, and the bond proceeds were placed with First City under the terms of a trust indenture. Continental executed a note in favor of Harris County. The financing documents included a loan agreement and a deed of trust under which Continental granted Harris County a security interest in the flight kitchen. The bonds were to be redeemed through Continental’s payment of the note.

The flight kitchen was built as scheduled and under budget. Under the financing documents, bond proceeds remaining after the completion of the project were to be used to redeem the bonds. Instead, Continental and Harris County entered into a purported amendment to the financing documents so that Continental could use the excess bond proceeds to construct a flight training center where the old flight kitchen stood. This new project was not subject to the deed of trust covering the flight kitchen construction.

Continental presented requisition certificates and draw requests to First City, and the bank distributed bond proceeds to Continental to construct the flight training center. First City eventually approved the disbursement of about $1.4 million for work done on the flight training center. Tellepsen was one of the contractors that Continental paid to furnish labor and materials for work on the flight training center. Tellepsen fully performed under its contract with Continental and was paid $73,719 out of the funds disbursed by First City.

After both facilities were completed, Continental, as it does occasionally, filed for bankruptcy. Continental owed Tellepsen $194,-674 at the time that it filed, and it had approved a requisition certificate for $147,-995, which it had submitted to First City. That certificate was not paid because of the bankruptcy, and Tellepsen recovered only $5,309.99 from Continental’s estate. Tellep[149]*149sen is the only contractor that was not fully paid on the flight training center project before the bankruptcy.

First City, as it does occasionally, failed, and it was seized by the FDIC. The trust funds still held by First City were transferred to its newest incarnation, New First City. That bank in turn was declared insolvent, and the trust funds were transferred to Texas Commerce Bank, where they rest.

3. The Claims.

The bondholders have settled with Harris County. They have now turned to the bank. They claim that First City breached the financing documents by (a) allowing an amendment that had a material, adverse effect on the bondholders without obtaining the bondholders’ consent, and (b) approving an amendment and disbursing funds without giving its prior written consent to the amendment and without granting the bondholders a lien on the new project.

The FDIC, standing in the shoes of First City, argues that (a) the amendment did not have a material and adverse effect on the bondholders, and (b) First City’s disbursements under the amendment operate to approve the amendment, which, it claims, the bondholders admit.

Tellepsen stipulates that it has no claim against the FDIC as receiver for First City but that it only wants the funds held in trust by Texas Commerce Bank. It wants the unpaid balance for its work on the flight training project of $189,364.01.

4. Material and Adverse.

The trust indenture allowed for two types of amendments, amendments that materially and adversely affect the interests of the bondholders and those that do not. See June 1, 1989, Trust Indenture Between Harris County Industrial Development Corporation and First City, Texas-Houston, N.A. §§ 901, 902. The amendment to the trust indenture was material and adverse to the bondholders, and by faffing to get their written consent, First City has breached the trust indenture.

The trust indenture requires the consent of the bondholders to an amendment to the financing documents that is material and adverse to their interests. • • Trust Indenture § 902(a). The FDIC explains why the use of the remaining bond proceeds for the training center was consistent with the trust documents: (a) the new project was not new, but a permissible modification, and (b) the amendment was not adverse.

Modification of the project under the loan agreement may take place without the bondholders’ consent. Trust Indenture § 901(g). The agreement allows for revision of the plans and specifications of the project as long as the result constitutes a “project” as the term is defined in the law. June 1, 1989 Loan Agreement Between Harris County Industrial Development Corporation and Continental Airlines, Inc. § 2.2. The section allowing a revision specifically refers to the description of the project in an exhibit to the agreement. Id.

The description is of a flight kitchen facility. It describes what the kitchen will contain, the dimensions and specifications of the building, and the site for the project. See Exhibit A to Loan Agreement. There is no mention of any other contemplated construction other than a new flight kitchen. There is simply no relationship between the flight kitchen and the flight training center, in this construction or in airline operation.

This obvious point was supported at oral argument by the FDIC’s assertion that the connection existed because the new flight training center was built where the old flight kitchen had been. That is patently absurd. Since the projects are wholly unrelated, the FDIC cannot take advantage of the clause allowing modifications to the project without the consent of the bondholders.

The amount expended on the flight training project was approximately $1.4 million, about seven percent of the face amount of the bonds. The FDIC asserts that this amount cannot be considered material. Since the entire amount of the bond proceeds was available for the flight kitchen construction, the expenditure ■ of an excess on the flight training center cannot be considered adverse.

[150]*150While some level of misapplication may be immaterial, $1.4 million is well above that level, whatever it may be. Any amount of the bond proceeds spent on an unauthorized project is presumptively material. Certainly, the FDIC would think it material if bank officials decided to pocket $1 million as a bonus for a job well done. The FDIC does not take the position that either the dollar amount or the percentage of the total is an acceptable standard of fidelity. An additional adversity to the bondholders of this expenditure is the lack of a hen placed on the earnings from the flight training center in favor of the bondholders. A hen on the flight kitchen proceeds was contractuahy obhgated.

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862 F. Supp. 146, 1994 U.S. Dist. LEXIS 12359, 1994 WL 477234, Counsel Stack Legal Research, https://law.counselstack.com/opinion/putnam-high-yield-municipal-trust-v-first-city-texas-txsd-1994.