Star Distillery Co. v. Mihalovitch-Fletcher Co.

9 Ohio N.P. (n.s.) 218
CourtOhio Superior Court, Cincinnati
DecidedMay 22, 1909
StatusPublished

This text of 9 Ohio N.P. (n.s.) 218 (Star Distillery Co. v. Mihalovitch-Fletcher Co.) is published on Counsel Stack Legal Research, covering Ohio Superior Court, Cincinnati primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Star Distillery Co. v. Mihalovitch-Fletcher Co., 9 Ohio N.P. (n.s.) 218 (Ohio Super. Ct. 1909).

Opinion

Hoffheimer, J.

The receivers of the Mihalovitch-Fletcher Company are engaged in selling, at public auction, the personal property of said defendant company. Included in said property is a certain automatic fire sprinkler system, which is fully described in paragraph 2 of the answer of the receivers to the intervening petition of Sallie F. Pritchard, the lessor. This sprinkler system, the receivers claim, was installed in lessor’s building by the Mihalovitch-Fletcher Company after the execution of a lease under which said defendant company occupied the premises-, and at a cost of $13,000.

The receivers contend that they are justified in severing and removing the component parts of the sprinkler system, for the reason that same is a trade fixture, and because said system was never annexed with the intention of making it a pai’t of the lessor’s property.

On the other hand, the lessor contends that said system is not a trade fixture, and furthermore, that the tenant (receivers) is debarred from the privilege of removing same, because the system was installed as a condition of the lease; that it was, part of the consideration thereof, and that the lease, itself, furnishes the basis upon which the rights of the parties must be detennined.

The question of determining whether or not an article affixed by a tenant to demised property is a trade fixture, has ever been a most perplexing one, and in the case at bar is further involved by the lease in question.

The lease in this case provides that:

‘ ‘ The lessee further agrees to equip the buildings on the within demised premises, front and rear, with an .automatic sprinkler [220]*220system at his own expense, work on the same to commence at once upon the execution of this lease. ’ ’

There was also the usual clause to deliver up the premises in good order, at the expiration of the term, damage from ordinary wear and tear excepted. The premises demised consisted of the realty (described by metes and bounds). And also—

“The factory buildings erected thereon, and all additions thereto that may be erected thereon during'the continuance of this lease; said premises being known as Nos. 516 and 518 East Pearl street, together with all boilers, engines and attachments and connections thereunto belonging, tanks, pumps, shafting, hangers, pulleys, belting, steam heating appliances and elevators situated therein.”

Even if this automatic fire sprinkler system was a thing which ordinarily would be held to be a trade fixture, inasmuch as the lessee may qualify or waive his right in regard thereto, the question would be, if this was a trade fixture, has the lessee waived his rights, if any, by the lease itself?

All that the lessee agreed to deliver up at the,end of the term is to be found in the description above set out. But certainly this automatic sprinkler system does not fall within any of the descriptive language used, unless, as- lessor (intervehor) insists, it comes within the meaning of the word “additions.”

But it is not an addition either under the evidence or within the technical significance of that term as defined by the authorities. The use of the words “erections” or “additions” in leases has a well defined meaning, and refers to buildings only. See Bronson on Fixtures, page 232, and cases cited.

The express language used by the parties themselves, therefore, would seem to indicate that the special covenant, although imposing a condition, did not contemplate that the thing to be done was to become, when done, an inseparable part of the freehold and hence to be delivered up at the end of the term as a part of the described premises. Hence, inasmuch as lessee was not to deliver it up, by fair implication, he had the right to remove it, provided it was a trade fixture. At any rate, the most that could be said would be that there is nothing in the lease itself regarding the removal of this article.

In the very recent case of Montello Brick Company v. Trexler, 167 Fed. Rep., 482 (February 15, 1909), there was a lease for a [221]*221long term of three brick plants and a separate tract of farm land, described as included therein the real estate, “together with all its brick plant works * # now held or owned or leased by lessor, or which ■ " # * may be acquired by lessor, and all erections; extensions or additions to the same which may at any time hereafter be located or constructed on the premises,” and required the lessee, on the termination of the lease, to return “the demised premises in good order and condition, with all improvements, additions and extensions, without any compensation to be paid for said improvements, additions and extensions.” And lessor and lessee were corporations, the stockholders and directors of which were the same. The lessee built on the farm land a new and extensive brick plant at a cost of $770,000, with borrowed money, which was unpaid when it became a bankrupt. It carried such plants on its books as an asset.

Held: That, especially in view of the relations between the parties; such provisions of the lease could not be construed to give the lessor the right to hold such plant,, as against the creditors of the bankrupt, and that the latter’s trustee was’entitled to remove it as a trade fixture.

In construing the lease there involved the Circuit Court of Appeals said:

“That the burden is on the lessor to show a clear intent to except this- trade fixture plant from the general trade fixture rule. That rule is one favored by courts, since it not only tends to foster trade, .but enables land owners to rent their land with advantages for its use by others. ’ ’

Certainly no such clear intent is shown here. Because, instead of the lease expressly declaring that the lessee was not to have the right to remove the automatic fire sprinkler system, we find peculiar language employed which not only, as already pointed out, takes the article when affixed out of the description of things to be delivered up at the end of the term, but, further, indicates that the sprinkler system was intended to be installed for temporary uses only. . ;

It will be noticed that the special covenant employs the word equip, which in its ordinary acceptation means to fit up for. a particular sei-vice or exigency (Webster).

For ordinary purposes and for ordinary business uses, this-factory was complete and ready for use and enjoyment. . ■

[222]*222But the exigency for which this building was to be equipped was the extra hazardous business of the lessee, who, according to the lease, was to use said building'“as a wholesale liquor and rectifying house.”

The equipment, therefore, had in view temporary protection incident to extra hazardous occupancy.' It was a use contemplated during the occupancy of the building as a wholesale liquor and rectifying establishment, and therefore the equipment could not have been in any sense for the permanent .benefit of the freehold.

If, then, the rule laid down by the Circuit Court of Appeals, which is the latest utterance I can find on the subject; expresses the true ride- (and it is certainly in keeping with the spirit of the modern decisions), I am unable to hold, even though the landlord imposed the installation.

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Bluebook (online)
9 Ohio N.P. (n.s.) 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/star-distillery-co-v-mihalovitch-fletcher-co-ohsuperctcinci-1909.