Abelmann v. SmartLease USA, L.L.C.

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SmartLease USA, LLC was a limited liability company with three principals, Kent Guthrie, Tony Marshall, and Steve Furst, which described itself in a business proposal as an entity seeking "to capitalize on the demand for quality housing [in the Williston Basin] by providing a high quality, exceptionally clean and professionally managed RV/mobile park" in partnership with a landowner. The Abelmanns owned farmland in the Williston Basin. They executed a written agreement to lease approximately 110 acres of their farmland to SmartLease for the stated purpose of "use as a short/long term RV (recreational vehicle), mobile home, cabin units, and truck parking." According to the Abelmanns, SmartLease agreed to develop the leased land into a high quality, clean, and professionally managed full service RV and mobile home park for housing and accommodations for the labor force in northwestern North Dakota. They claimed SmartLease started to develop the land, but thereafter neglected its obligations under the written lease. They claimed SmartLease failed to pay them rent or the security deposits required by the lease and failed to provide proper management for the land. According to them, a property manager hired by SmartLease, Aaron Smith, failed to provide proper on-sight management for the property and eventually quit, which resulted in no on-site management for the property. The Ablemanns claimed they provided SmartLease with written notice of termination of the lease in February 2013, and claimed SmartLease refused to vacate the premises and attempted to transfer the lease to a third party. In May 2013, the Abelmanns served SmartLease with a notice of intention to evict. The Abelmanns appealed the dismissal of their eviction action against SmartLease. The Abelmanns argued the district court erred as a matter of law in construing their written lease with SmartLease and in determining any breaches of the lease by SmartLease were immaterial and of nonessential terms. The Supreme Court agreed, reversed and remanded. The Court concluded the district court erred in interpreting the purpose of the parties' lease and failed to make adequate findings to understand the basis for its decision. View "Abelmann v. SmartLease USA, L.L.C." on Justia Law