Spectra-4, LLP v. Uniwest Commercial Realty

CourtSupreme Court of Virginia
DecidedJune 4, 2015
Docket140892
StatusPublished

This text of Spectra-4, LLP v. Uniwest Commercial Realty (Spectra-4, LLP v. Uniwest Commercial Realty) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spectra-4, LLP v. Uniwest Commercial Realty, (Va. 2015).

Opinion

Present: All the Justices

SPECTRA-4, LLP, ET AL. OPINION BY v. Record No. 140892 JUSTICE LEROY F. MILLETTE, JR. June 4, 2015 UNIWEST COMMERCIAL REALTY, INC.

FROM THE CIRCUIT COURT OF FAIRFAX COUNTY Michael F. Devine, Judge

In this appeal we determine to what extent implied-in-fact

contracts encompass the terms of previously expired express

contracts that were not executed by the parties to the implied-

in-fact contracts.

I. FACTS AND PROCEEDINGS

Spectra-4 LLP and Spectet Limited Partnership, LLP are

limited liability partnerships that individually own and lease

neighboring commercial buildings in Reston, Virginia. This

appeal arises out of a dispute over the management services

provided for the commercial buildings.

1. History Of Management Services

Relevant to this appeal, three separate entities have

provided the management services for the commercial buildings.

First, Jefferson/LBG, L.L.C. managed the commercial

buildings from 1995 to 1997. Jefferson/LBG was organized in

August 1995 and was owned in part by Suzanne O. Farr.

Jefferson/LBG's management services were governed by two

separate but materially identical Management Agreements, one for each commercial building. Spectra-4 and Jefferson/LBG

executed the Management Agreement pertaining to the commercial

building owned by Spectra-4, and Spectet and Jefferson/LBG

executed the Management Agreement pertaining to the commercial

building owned by Spectet. The corporate existence of

Jefferson/LBG was automatically cancelled by the Virginia State

Corporation Commission in December 1997 when it failed to pay

its annual registration fee.

Second, Jefferson Commercial Real Estate Services, Inc.

managed the commercial buildings from 1998 to 1999. Farr was

also an owner of Jefferson Commercial, but despite their

similar titles, Jefferson Commercial was a separate entity

legally distinct from Jefferson/LBG. No new Management

Agreements were executed to govern Jefferson Commercial's

management services for the commercial buildings. Also,

Jefferson Commercial did not transact any business with

Jefferson/LBG.

Third, Uniwest Commercial Realty, Inc. managed the

commercial buildings from 2000 until 2012. No new Management

Agreements were executed to govern Uniwest's management

services for the commercial buildings. Also, Uniwest did not

transact any business with Jefferson/LBG. However, Uniwest did

transact business with Jefferson Commercial. Uniwest and

Jefferson Commercial executed an Asset Purchase Agreement in

2 November 1999 in which Jefferson Commercial sold all of its

assets, but no stock, to Uniwest.

2. Uniwest's Tenure In Providing Management Services

Jefferson Commercial notified Spectra-4 and Spectet that

it added Uniwest "as partners" to its management services

effective January 2000. At that time, Farr became Uniwest's

president. Later, in 2002, Uniwest fired Farr from this

position. Despite this change, Uniwest continued to provide

management services for the commercial buildings until 2012.

In September 2012, Spectra-4 and Spectet notified Uniwest

that they sought to "terminate[] the [M]anagement

[A]greement[s] between Uniwest and [Spectra-4 and Spectet]."

Uniwest responded that the termination was "invalid per the

terms of the [Management] Agreement[s]," and stated that it

would continue its management services until certain specified

dates. Legal counsel then became involved, and after a series

of letters sent back and forth, Uniwest's management services

for both commercial buildings were terminated in October 2012.

Following the termination of its management services, Uniwest

withdrew $13,847.61 in premature termination fees from Spectra-

4's operating accounts, and $22,605.72 in premature termination

fees and $1,751.30 in copying costs from Spectet's operating

accounts.

3 Uniwest withdrew these funds because it believed that it

was entitled to such fees and costs upon what Uniwest

considered to be Spectra-4's and Spectet's premature

termination of Uniwest's management services. Uniwest's

position was predicated upon its belief that the Management

Agreements themselves dictated the contractual relationships

between Spectra-4 and Uniwest, and between Spectet and Uniwest;

or, alternatively, that the contractual relationships between

the parties had incorporated the full terms of the Management

Agreements. In contrast, Spectra-4 and Spectet believed that

Uniwest's withdrawal of such fees and costs was impermissible.

Spectra-4's and Spectet's position was predicated upon the

belief that the Management Agreements did not govern Uniwest's

management services; and that even if the Management Agreements

did govern, Spectra-4 and Spectet had complied with the "just

cause" termination clause of those agreements in terminating

Uniwest's management services.

3. Judicial Proceedings

Upon learning that Uniwest had withdrawn additional fees

and costs, Spectra-4 and Spectet filed separate Warrants in

Debt against Uniwest in the General District Court of Fairfax

County, alleging conversion. The cases were not consolidated,

but a single trial was held and the district court awarded

judgment in favor of Spectra-4 and Spectet.

4 Uniwest timely appealed to the Circuit Court of Fairfax

County, and Spectra-4 and Spectet amended the complaints to

include breach of contract claims. Once again, the cases were

not consolidated but a single trial was held. After a bench

trial the circuit court requested additional briefing on

Uniwest's renewed motion to strike. Upon considering the

parties' arguments and briefs, the circuit court entered

judgment in favor of Uniwest and dismissed Spectra-4's and

Spectet's claims with prejudice.

Spectra-4 and Spectet timely appealed to this Court.

II. DISCUSSION

Although we granted three assignments of error, we need

only address the first assignment because our determination of

the terms of the implied-in-fact contracts governing the

parties' relationships resolves this appeal. 1 Jimenez v. Corr,

288 Va. 395, 404, 764 S.E.2d 115, 118 (2014).

1 Assignment of error 2 pertained to whether Spectra-4 and Spectet waived their right to terminate management services under the Management Agreements' "just cause" termination clause. Assignment of error 3 pertained to whether Spectra-4 and Spectet could waive any portion of the Management Agreements by conduct, rather than by writing, despite the waiver-only-in- writing clause in the Management Agreements.

5 Assignment of error 1 reads:

1. The trial court erred in holding that the implied-in-fact contracts between [Spectet and Spectra-4] and [Uniwest] "effectively incorporated the terms of the [Management Agreements]" and, thus, that [Uniwest] did not breach the implied-in-fact contracts by taking liquidated damages from [Spectet and Spectra-4] equal to six months' management fees and charging [Spectet] for copy costs.

A. Standard Of Review

"The question of whether [a valid] contract exists is a

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