Woodard v. Wiltshire

21 Va. Cir. 295, 1990 Va. Cir. LEXIS 464
CourtCharlottesville County Circuit Court
DecidedSeptember 27, 1990
DocketCase No. (Law) 3890
StatusPublished

This text of 21 Va. Cir. 295 (Woodard v. Wiltshire) is published on Counsel Stack Legal Research, covering Charlottesville County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Woodard v. Wiltshire, 21 Va. Cir. 295, 1990 Va. Cir. LEXIS 464 (Va. Super. Ct. 1990).

Opinion

By JUDGE JAY T. SWETT

This matter was tried without a jury September 13, 1990. Based upon the evidence taken during trial, the court makes the following factual findings.

Plaintiffs, Keith O. and Elaine A. Woodard (hereinafter "Woodard") entered into a two-year lease with defendant George Wiltshire (hereinafter "Wiltshire"). The lease was for Suite 1 at the Exchange Center on the Mall in Charlottesville. The lease ran from November 1, 1985, to October 31, 1987. Wiltshire leased the premises to operate a retail store known as "The Pewter Corner." The lease was to terminate October 31, 1987, unless Wiltshire requested in writing, no later than 120 days prior to October 31, 1987, that the lease be renewed for an additional three-year term. Under the renewal provision, the rent would increase each year for the three-year renewal term.

In May of 1987, Woodard and Wiltshire discussed whether Wiltshire would renew the lease beyond October 31, 1987. Wiltshire expressed concern that the rent was too high and asked Woodard for a reduction. While Woodard and Wilt-shire differ on their recollection of whether Woodard agreed to reduce the rent if Wiltshire renewed, they did not agree on a new lease during the meeting. Woodard prepared a new lease proposal and provided it to Wiltshire. [296]*296The proposal was for a renewal of two years with rent at $1,250.00 per month. Under the old lease, Wiltshire was paying $1,200.00 per month. If Wiltshire renewed the old lease, he would pay $1,280.00 per month the first year, $1,344.00 per month the second year, and $1,411.20 per month the third year.

After Woodard sent Wiltshire the proposal for a two-year lease, there were few, if any, substantive discussions between them about the new lease agreement. On July 22, 1987, Wiltshire wrote to Woodard asking Woodard to explore the local rent market. Wiltshire wrote that if they were unable to reach an agreement, that Wiltshire wished to stay through Christmas. He proposed he remain as a month-to-month tenant beginning on November 1, 1987. Woodard does not recall receiving the letter.

In August Woodard met with an employee of Wiltshire to discuss the lease renewal. As of that meeting, Wiltshire had not given the required written notice under the renewal clause of the old lease. Other than return a copy of Woodard’s two-year proposal with changes proposed by Wiltshire, nothing was accomplished during the August meeting.

On October 27, 1987, four days before the lease was to expire, Woodard and Wiltshire spoke about Wiltshire remaining as a tenant. Woodard testified that Wiltshire continued to object to the $1,250.00 per month demanded by Woodard. Wiltshire again suggested he stay on as a month-to-month tenant while they continued to negotiate. Woodard testified that he turned Wiltshire down. Wiltshire testified that Woodard said Wiltshire could stay on ás a tenant from month-to-month while they continued to negotiate.

Two days later, on October 29, Woodard wrote Wiltshire enclosing another proposal for a new lease. He told Wilt-shire that if the proposed lease was not executed and Wiltshire held over after November 1, 1987, that Woodard would consider Wiltshire as having elected to renew the lease for a three-year term under the provisions of the old lease.

Wiltshire responded by letter of November 3. He rejected Woodard’s proposal and submitted a counter proposal. He paid $1,200.00 rent for November. Woodard responded on November 6, 1987, with a notice of default and notice to vacate on the grounds that Wiltshire had not paid [297]*297$1,280.00 in rent which Woodard claimed was called for under the renewal provision of the original written lease agreement. Wiltshire responded to the notice to quit by telling Woodard that he intended to stay month-to-month until evicted. Woodard took no action to evict him.

On December 1, 1987, Woodard wrote Wiltshire advising him again that he was in default. Wiltshire wrote back on December 5 and disputed Wiltshire's claim of the rent due and confirmed that he was occupying the space on a month-to-month basis. Wiltshire paid $1,200.00 for December rent. The check was returned by Woodard on the basis that the rent was $1,280.00 per month. In January, 1988, Wilt-shire paid Woodard $100.00 for January rent taking the position that the balance of his security deposit, $1,100.00, would cover the balance of the rent due for January. Wiltshire vacated effective January 31, 1988, pursuant to written notice that he had given on December 18, 1987.

Based upon this evidence, the issue is whether there exists a three-year lease, a month-to-month lease, or a year-to-year lease. Woodard contends that by holding over after receipt of Woodard's October 29, 1987, letter, Wiltshire elected to accept Woodard’s offer to renew for a three-year term, under the provisions of the 1985-1987 lease. Woodard argues in the alternative that if there is no three-year lease, then Wiltshire’s act of holding over creates a lease from year-to-year and Wiltshire is liable for unpaid rent and other damages through October 31, 1988. Wiltshire argues that he and Woodard agreed that Wiltshire would lease the premises on a month-to-month basis after November 1, 1987, and that Woodard is entitled to nothing.

In Virginia, the general rule is that a tenant who holds over under a lease for a term of years following the expiration of the term becomes a tenant from year to year. Rubin v. Gochrach, 186 Va. 786, 794 (1947); Elliott v. Birrell, 127 Va. 166, 170 (1920). On the other hand, where there is a lease for a term of years which contains a right for the tenant to renew for an additional term of years at an increased rent, then a tenant who holds over and pays the increased rent will be deemed to have agreed to the terms of the extension of the original lease. Crowder v. Virginia Bank, 127 Va. 299, 302-303 (1920).

[298]*298Here, Wiltshire did not invoke his right to renew his lease for a three-year term effective October 1, 1987. On the contrary, the evidence is clear that Wiltshire did not wish to exercise his right to renew and wished to continue occupying the premises only if he could obtain an agreement to do so at a reduced rent. Under the express terms of the lease agreement, the lease would "automatically terminate at the expiration of the term" unless the lessee invoked his right to renew in writing. Since Wiltshire did not invoke his right to renew, the lease terminated on October 31, 1987, by its own terms. Accordingly, Crowder, supra, does not apply. In Crowder, the tenant had a two-year lease with the right to extend for two years. At the expiration of the first two-year term, the tenant held over without saying anything to the landlord and continued to pay rent for nine months at the increased rate. The tenant then gave a notice to vacate in three months arguing that his tenancy was a hold-over from year to year. The Court rejected this argument finding that the tenant had exercised his privilege to renew and that the only basis under which he could renew was for the two-year term. Here, the evidence is clear that Wiltshire did not act in any way consistent with his desire to extend the original lease for the three-year renewal term.

Wiltshire did hold over hy remaining in the space after November 1, 1987. Wiltshire argues that he did so under an agreement with Woodard that he would occupy the premises on a month-to-month basis.

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Related

Elliott v. Birrell
102 S.E. 762 (Supreme Court of Virginia, 1920)
Crowder v. Virginian Bank of Commerce, Inc.
103 S.E. 578 (Supreme Court of Virginia, 1920)
Rubin v. Gochrach
44 S.E.2d 1 (Supreme Court of Virginia, 1947)

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Bluebook (online)
21 Va. Cir. 295, 1990 Va. Cir. LEXIS 464, Counsel Stack Legal Research, https://law.counselstack.com/opinion/woodard-v-wiltshire-vacccharlottesv-1990.