Union III v. Momentum Marketing

CourtColorado Court of Appeals
DecidedOctober 24, 2024
Docket23CA2119
StatusUnpublished

This text of Union III v. Momentum Marketing (Union III v. Momentum Marketing) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Union III v. Momentum Marketing, (Colo. Ct. App. 2024).

Opinion

23CA2119 Union III v Momentum Marketing 10-24-2024

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA2119 Jefferson County District Court No. 22CV31256 Honorable Randall C. Arp, Judge

Union III, LLC, a Colorado limited liability company,

Plaintiff-Appellee,

v.

Momentum Marketing Solutions, Inc., a Pennsylvania corporation, and Matthew John Lafferty

Defendants-Appellants.

JUDGMENT AFFIRMED IN PART, REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division III Opinion by JUDGE RICHMAN* Dunn and Navarro, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 24, 2024

Hatch Ray Olsen Conant LLC, Brian T. Ray, Denver, Colorado, for Plaintiff- Appellee

Fennemore Craig, P.C., Mallory P. Nordberg, Denver, Colorado, for Defendants- Appellants

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2024. ¶1 Defendants, Momentum Marketing Solutions, Inc.

(“Momentum”) and Matthew John Lafferty appeal the district court’s

entry of judgment and the award of damages in favor of Union III,

LLC (“Union III”). We affirm in part and reverse in part, and we

remand the case with directions.

I. Background

¶2 On June 23, 2021, Union III, a commercial landlord, and

Momentum, a direct marketing firm owned by Lafferty, entered into

a written commercial lease for the property located at 1350

Independence Street, Suite 301, Lakewood, CO 80215. Lafferty

executed a personal guaranty making him “jointly and severally,

unconditionally and irrevocably” liable for Momentum’s execution of

the lease with Union III.

¶3 The lease term ran from July 1, 2021, through June 20, 2024.

However, on August 30, 2021, Lafferty informed Union III that

Momentum had gone out of business, and he would be unable to

pay the rent due on September 1, 2021. Union III provided Lafferty

with options for lease termination, but Lafferty did not respond.

¶4 On September 8, 2021, Union III provided defendants with a

Notice to Quit, which required that within the next seventy-two

1 hours defendants either pay the past due rent and late fee, or

otherwise vacate the premises. Defendants chose to vacate the

premises.

¶5 On October 6, 2021, Union III sent defendants a document

stating that it did not consider the lease to be terminated. However,

Union III listed the property for lease at a per square foot rate

slightly above what Momentum’s lease had provided, and eventually

procured a replacement tenant, whose lease term began on July 1,

2023.

¶6 In November 2022, Union III initiated this action for breach of

the lease against Momentum and breach of the guaranty against

Lafferty. Union III moved for summary judgment on the issue of

liability, which the district court granted. However, the court

determined that testimony was needed to determine the amount of

damages and it held a separate bench trial for that determination.

¶7 Following the trial, the district court issued a thorough and

well-reasoned order and judgment as to the amount of damages.

¶8 The court concluded that Union III terminated the lease on

September 8, 2021. The court then concluded that Union III took

reasonable and appropriate steps to mitigate its damages, including

2 removing defendants’ leftover property, relisting the property for

lease at a reasonable rate, and replacing the carpet. After

determining that Union III’s damages were limited to one of the

remedy provisions in the lease, the district court detailed its

findings for Union III’s rent-related and non-rent related damages.

¶9 On appeal, defendants assert that (1) the district court erred

by interpreting the lease’s term “reasonable rental value” to mean

the amount of rent Union III received from the replacement tenant;

(2) the district court erred by finding that Union III was entitled to

late fees on its damages; (3) the district court erred by awarding

Union III damages for its expense to recarpet the premises; and (4)

the district court erred by finding that defendants were not entitled

to a reduction of the damages they owed Union III for the months of

July through September 2023. We address each contention in

turn.

II. “Reasonable Rental Value”

¶ 10 Defendants first contend that the trial court erred by

interpreting the term “reasonable rental value” to mean the amount

of rent Union III actually obtained from the replacement tenant. We

are not persuaded.

3 A. Standard of Review and Applicable Law

¶ 11 “A landlord’s claim against a tenant for breach of a commercial

lease is a breach of contract claim that ‘requires nothing more than

application of established principles of contract law.’” Tremitek, LLC

v. Resilience Code, LLC, 2023 COA 54, ¶ 19 (quoting Schneiker v.

Gordon, 732 P.2d 603, 612 (Colo. 1987)).

¶ 12 The interpretation of a contract is a question of law we review

de novo. French v. Centura Health Corp., 2022 CO 20, ¶ 24.

However, we defer to the district court’s factual findings unless they

are clearly erroneous — meaning they have no support by the

record. Cronk v. Bowers, 2023 COA 68M, ¶ 12.

¶ 13 When interpreting a contract, our primary goal is to give effect

to the parties’ intent. French, ¶ 25. We discern that intent

primarily from the language of the contract itself. Id. We first

determine whether the contract terms are ambiguous, which we do

by examining the contract language and construing that language

based on the plain and generally accepted meaning of the words.

Id. If the contract is unambiguous, we will enforce it as written. Id.

However, if the contract is ambiguous, insofar as the terms are

susceptible to more than one reasonable interpretation, then

4 extrinsic evidence is admissible to establish the parties’ intent. Id.

But the mere fact that the parties disagree about a contract’s

interpretation does not itself establish ambiguity. Id.

¶ 14 Typically, the proper measure of damages in such an action is

“the amount it takes to place the landlord in the position [it] would

have occupied had the breach not occurred, taking into account the

landlord’s duty to mitigate.” Tremitek, ¶ 19 (internal quotation

omitted). The duty to mitigate means that a landlord cannot “sit by

idly and suffer avoidable economic loss.” Id. at ¶ 20 (citing

Schneiker, 732 P.2d at 610). Rather, a landlord fulfills its duty to

mitigate if it makes “reasonable efforts” to reduce the damages

sustained. Id. (internal quotation omitted). Ordinarily, this means

the landlord must “exercise reasonable efforts to procure a

substitute tenant” — including by taking “some affirmative steps” to

do so. Id. (quoting Pomeranz v. McDonald’s Corp., 821 P.2d 843,

847 (Colo. App. 1991), aff’d in part and rev’d in part on other

grounds, 843 P.2d 1378 (Colo. 1993)).

¶ 15 The tenant bears the burden of proving the landlord failed to

mitigate damages. Id. at ¶ 22.

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Bluebook (online)
Union III v. Momentum Marketing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-iii-v-momentum-marketing-coloctapp-2024.