Implied covenants of continuous occupancy in shopping centers.
What is the worst thing that can happen to a shopping center? A flood? A fire? A tornado? Probably not. There is generally insurance available to cover the damage caused by such disasters. However, there is no such protection when a shopping center loses its anchor tenant, and the damage can be every bit as severe.
Often the only protection is an implied covenant of continuous occupancy (ICCO). Establishing that an ICCO exists is no easy proposition, and even if the owner is successful, he or she must then confront the difficult task of proving damages.
ICCOs have been a subject of judicial strife and inconsistency for many years. Unfortunately, the courts have failed to articulate a uniform formula for determining whether they exist in any particular situation. The determination is made on a case-by-case basis, and it is extremely difficult to predict the outcome.
The subject of damages has received even less judicial attention. Until the Nevada Supreme Court's recent decision in Hornwood, there was no case which even considered whether a owner could recover the amount by which a shopping center declined in value as the result of the anchor tenant's departure. This landmark decision opens the door for the owner to recover all damages which were a consequence of the anchor's breach of an ICCO.
Of course, even an ICCO offers little protection if the anchor simply goes bankrupt. In that event, there is little the owner can do. However, anchors are sometimes motivated by profit considerations when making the decision to "go dark." The anchor concludes that a greater profit can be made by closing its operation within the shopping center and subletting the space.
Subletting is particularly profitable for an anchor because its minimum base rent is usually less than that of other tenants in the center. Thus, if the anchor is free to sublet, it can carve up its space for a number of satellite tenants and make a substantial profit for the balance of the lease term.
In the normal landlord/tenant relationship, there is nothing objectionable about a tenant vacating in mid-term so long as the rent continues to be paid. For this reason, it is often difficult to convince a judge that such action by an anchor is a different situation altogether-one which results in severe financial consequences for the entire shopping center.
As everyone within the industry knows, the primary function of an anchor is to draw customers into the center. This, in turn, attracts satellite tenants, increases their business, and enables the landlord to charge higher rents, resulting in an overall enhancement of the value of the shopping center. When an anchor vacates, all of this is reversed. Moreover, the landlord will in all probability be deprived of future overages(2) (i.e., percentage rent) that would have been paid had the anchor remained in business.
Under such circumstances, what can an owner do? The first consideration is whether the lease contains an implied covenant of continuous occupancy. (Of course, all is well if the developer had the foresight to incorporate into the lease an express covenant that the tenant would remain within the premises and conduct its business during the full term of the lease.) If an ICCO exists, the second consideration is, what remedies are available to the landlord? An analysis of the Homwood case is an appropriate starting point.
Hornwood v. Smith's Food King On November 1, 1986, Smith's Food King vacated its grocery store premises at the Spring Mountain & Jones Shopping Center in Las Vegas. The owners, Sanford and Rita Hornwood, then filed suit against Smith's, claiming that Smith's conduct was a breach of the lease and that the center suffered various damages including a decline in value by $1.425 million as a result of losing its major tenant.
The principal issue at trial was whether the lease contained a covenant of continuous occupancy. The lease provided that Smith's would continuously conduct and carry on "tenant's business" within the premises throughout the term of the lease. Extrinsic evidence demonstrated that "tenant's business" was a grocery store operation. Moreover, the lease prohibited the tenant from vacating or abandoning.
Based on these and other provisions within the lease, the trial court found that a covenant of continuous occupancy existed and concluded that Smith's had breached that covenant. However, the trial court refused to award the owners any damages whatsoever, principally on the basis that such damages were viewed as unforeseeable. Adding insult to injury, the trial court awarded Smith's, the breaching party, 45,000 in attorneys' fees.
On April 25, 1989, the Nevada Supreme Court upheld the conclusion that Smith's breached its agreement to operate a supermarket during the entire term of the lease, but reversed on the issue of damages. The district court was directed to award the Hornwoods all damages that they suffered as a consequence of Smith's departure. The court also reversed the award of attorneys' fees and instructed the trial judge to award the Hornwoods their attorneys' fees.
Smith's decision to close its store at Spring Mountain & Jones was part of an overall plan to convert its supermarkets from traditional-size stores to larger "superstores." At other shopping centers throughout the West, Smith's either increased the size of the existing store or vacated (sometimes moving into a new shopping center directly across the street). The detrimental impact on the vacated centers has been obvious. Other tenants have moved out, and the traffic is minimal.
The Hornwood case provides a new remedy for shopping center owners who have lost an anchor tenant. However, they must first establish that the tenant expressly or implicitly agreed to continuously occupy the premises. Unfortunately, the case law in this area fails to provide a formula which will produce consistent results. Thus, the outcome is difficult to anticipate, and most cases will have to be litigated to conclusion.
What gives rise to an ICCO?
It is often stated that implied covenants are not favored in the law? Courts are particularly reluctant to "read between the lines" when considering a comprehensive written contract negotiated by sophisticated business executives. Thus, an express covenant is far superior! Nevertheless, there are many leases in existence today where the parties simply assumed that the tenant would remain in business throughout the entire term. That assumption can at times be gleaned from the terms of the lease or from the surrounding circumstances, leading to an ICCO finding.
Unfortunately, there is no consensus among the courts concerning the precise facts under which an ICCO will arise. At one extreme, courts refuse to consider any understanding" between the parties which was not specifically expressed in the lease. On the other hand, at least one court has held that whenever a tenant has agreed to pay overages, there is an implied covenant of good faith, which mandates that neither party will do anything which will interfere with the maximization of gross sales (and therefore percentage rent) ?
Generally speaking, a court will consider a number of elements in deciding whether an ICCO exists. The determinative factors are generally the "use" provision; the ratio between minimum and percentage rent; and the restrictions, if any, on subletting.
Some courts also place emphasis on whether the premises were built to suit, whether the landlord agreed to restrict competition within the center, whether vacating or abandonment constitutes a default, and what may have been said during the negotiations that led up to the signing of the lease.
Although some courts have set forth a formula for determining whether an ICCO exists, it is so vague that two different courts considering identical facts can reach opposite conclusions. Regardless of this unfortunate state of affairs, the factors are important.
The use provision. The use provision is often the controlling factor in determining whether an ICCO exists. The rhetorical question which is often posed is whether the use is "permissive" or restrictive." In other words, does the lease permit the tenant to use the premises for a specified purpose or does it restrict its use to that purpose only?
In EMRO Marketing, the use provision was viewed as restrictive. Based on this finding and the additional fact that overages constituted a substantial portion of the rent (discussion follows), an ICCO was deemed to exist. On the other hand, courts have refused to find an ICCO where the lease provides for any use" of the premises(8) or for any other commercial purpose."(9)
Several courts have held that a provision authorizing a particular use does not necessarily restrict the tenant to that use only.(10) Even the phrase, "for the purpose of conducting thereon a retail department store;' has been held permissive.(11) Carrying this view to an extreme, one court held that the phrase "will use as a bank' was permissive and refused to find a breach when the bank subleased to another business.(12)
* Minimum rent versus percentage rent.
The rent provisions within a lease and the tenant's past rent payments are important considerations in deciding whether an ICCO exists. The reason for this is clear if we examine the extremes. One would expect a court to find an ICCO where a tenant's rent was percentage only (based solely on gross sales). It would be unfair to allow the tenant to close its business and lock the doors without any recourse being available to the landlord.
On the other hand, where the minimum base rent is relatively high and overages are a remote possibility, a tenant would pay the same whether opened or closed. Thus, there is less reason to find an ICCO. The difficulty arises because most cases fall somewhere in between.
Courts have refused to find ICCOs where percentage rent had never been paid,13 where percentage rent was paid only once in 11 years,(14) and where percentage rent was deemed "not significant."(15) Courts are particularly reluctant to find an ICCO where there is no percentage rent provision within the lease
On the other hand, ICCOs have been found where the minimum rent does not represent a fair return for the tenant's use of the property.(17) Base rent of one-third the fair rental value has been viewed as "grossly inadequate;' leading to the finding of an ICCO.(18) A similar result was reached where the minimum rent was only $100 per month for property worth 30,000 and where the percentage rent was substantial.(19)
* Assignability. The assignability issue generally arises when the tenant argues that the right to assign negates an ICCO.(20) This appears to be the case where the lease does not address as signability at all,(21) or where the tenant has been granted the right to assign without the landlord's consent?2
In the more common situation, however, a provision allowing the tenant to assign or sublet only with the landlord's consent does not, in and of itself, negate the possibility of an ICCO(23) Moreover, the landlord can reasonably withhold consent where the new tenant will not generate an equivalent percentage rent,(24) where the new tenant's business is not compatible with the existing businesses within the center,(25) or where the new tenant cannot demonstrate financial responsibility(26)
* Miscellaneous considerations. Courts have taken into consideration several additional factors from time to time in deciding whether to find an ICCO. For example, the fact that the leasehold premises were built specifically to suit the tenant has been regarded as an important factor(27)
Another relevant consideration is whether the landlord has contractually agreed not to lease space to other similar types of businesses within a center(28) Indeed, it would seem to be inherently unfair to allow the tenant to discontinue operations and sublease to a different type of business, yet continue to enforce the non-compete clause within its lease.
Many leases also contain a provision which prohibits the tenant from vacating or abandoning the leasehold premises. Such provisions standing alone do not give rise to an ICCO.(29) Nevertheless, when a tenant goes dark without a sublessee to take over the space, it is certainly arguable that the tenant is in default, triggering a breach and justifying termination or damages regardless of whether the lease contains an ICCO.(30)
Entwined among all of these considerations is the parol evidence rule, which prohibits the introduction of any evidence which would tend to alter or negate the terms of a comprehensive written contract. Where the lease is unclear or ambiguous, it is an error for the trial court to dismiss the landlord's complaint without a hearing to determine the parties' intent.(31) But if the lease is clear and does not require the tenant to continuously occupy the premises, the court can exclude parol evidence and decline to find an ICCO as a matter of law?(32)
* Summary. Unfortunately, many of the cases appear to be result oriented; that is, the court concludes there should not be an ICCO (possibly because of the type of relief the landlord is seeking) and then justifies that outcome by stating, for example, that the base rent is substantial.
Reaching the same result by a different path, some courts have blindly applied the rules of contract law, ignoring assumptions that both parties obviously made when they entered into the lease and disregarding the financial consequences that often befall the owner and other tenants in a shopping center when the anchor departs. This duplicity has led to inconsistent rulings and a jumble of legal principles.
An example is Mercury Investment CO. v. FW. Woolworth The court viewed the base rent as substantial because the tenant had never before paid percentage rent, and on that basis refused to find an ICCO. However, the fact that percentage rent had not been paid as of the date of vacating should not mean that it was not an important element in the negotiations or that a substantial sum would not be paid over the balance of the lease term. The court appeared to be more influenced by the fact that the landlord was attempting to terminate the lease because the tenant had not generated "more business.' As discussed below, courts are reluctant to provide such a remedy.
What remedies are available?
Owners pursue different remedies for different reasons. Some may want the lease terminated so they can re-lease to another anchor. Others seek an injunction or damages because there are no other anchor tenants available. The outcome of a case involving a ICCO breach often depends on the nature of the remedies sought.
Forced productivity. Landlords who have sought court intervention in order to force the tenant to alter business operations in a manner which will allegedly result in increased sales (and therefore greater percentage rent) have generally met with failure. As stated in Mercury Investment, a court will not order a tenant to do "more business One court has gone so far as to hold that an ICCO is not breached where the tenant closes down one-half of its business operations.(35)
* Termination. Where the lease is silent regarding the right of the tenant to sublet, the act of subletting to a different business without the owner's permission does not entitle the landlord to terminate the lease. A similar conclusion has been reached where the lease authorized a specific use or any other commercial purpose:(36) Where, however, the use" term is viewed as restrictive and the overages are a substantial portion of the rent, the landlord is entitles to enforce the contractual remedy of termination(37)
* Injunctive relief. For the outcome of a lawsuit for injunctive relief will depend on whether an ICCO is found to exist. But even when there is such a finding, some trial judges have expressed reluctance to enjoin a tenant from vacating because of the apparent need for constant judicial supervision.
The leading cases for injunctive relief are Dover Shopping Center, Inc., v. Cushman's Sons, InC.(38) and Ingannamorte v. King's Super Markets, Inc.(39) In Dover, the court placed a great deal of reliance on two factors: the percentage rent provision (holding that it implied an obligation to use diligence) and the disruption that the tenant's departure would have on a cooperative enterprise like a shopping center. On this basis, an injunction was granted. A similar conclusion was reached in Ingannamorte even though there was no percentage rent provision in the lease.
Other important considerations for granting relief include a non-compete clause in the lease(40) and the potential damage to other tenants that generally have no recourse against a departing tenant.(41) But where the use provision is permissive and no ICCO exists, injunctive relief is inappropriatey(42)
* Damages. Under time-honored principles of contract law, the proper measure of damages should be the amount it takes to place the owner in the position he or she would have been in had the breach not occurred.(43) This definition of damages may include the owner's loss of anticipated profitS(44) and the difference between the worth of the property with the lease and the worth of the property without the lease.(45)
Where a departing tenant continues to pay a minimum base rent, an important consideration is whether the owner will suffer a loss of future percentage rent. If a tenant subject to an ICCO has paid percentage rent on a consistent basis in the past, courts generally do not hesitate to require a like payment for the balance of the term!(46)
One court has even commented that the jury can consider the tenant's probable lack of enterprise and promotional zeal during the recent years because of the contemplated move to a better location.(47) Percentage rent may even be recoverable where the tenant is newly established and has no track record!8 Percentage rent is generally not recoverable unless an ICCO is present.(49) However, in Bastian v. Albertson's(50) percentage rent was awarded anyway. The anchor tenant supermarket had vacated its store and left it empty. Although the court acknowledged that there was not an implied covenant of continuous occupancy, it nevertheless held that the tenant was obligated to continue paying fair and adequate rent. Thus, damages were awarded to the owner including the minimum rent, plus the percentage rent which would have been generated.
An interesting situation arises when a tenant moves to a nearby location. Should future percentage rent be based on past gross sales, anticipated gross sales at the old location, or actual gross sales at the new location? In Slidell,(51) the tenant breached an ICCO when it moved into a new location directly across the street "for its own economic benefit'" The tenant was held liable for percentage rent based on gross sales at the new location. However, a contrary result was reached in Downtown Associates, Ltd. v. Burrows Bros.
When an anchor closes, this will generally result in reduced gross sales for the remaining tenants and a reduction in their percentage rent as well. This series of events has been termed the "Tiffany effect;' and at least two courts have held that this loss of future rents from other tenants can be an element of the landlord's damages?
When an anchor tenant breaches an ICCO, the impact may be far greater than unpaid percentage rent and general disruption within the center. The loss of an anchor can transform a major shopping center into a ghost town. For anyone who has attempted to obtain financing for a shopping center, it is quite clear how much emphasis lenders place on an anchor. They rely heavily on this particular tenant because they know that an anchor's presence greatly enhances a center's value. Its absence, of course, has the opposite effect.
Until Hornwood v. Smith's Food King, no appellate case addressed the issue of whether an owner could recover for diminution in value of the center where an anchor tenant has vacated. Other cases contained analogous rulings,(54) but none appeared on point. Now the owner can introduce before-and-after appraisals in an effort to recover the amount by which a property declined in value as a result of the anchor's departure.
Owners should not overlook other potential damages. For example, in addition to the devaluation which takes place the moment the anchor leaves, there may be expenses relative to the hardship reaped on the other tenants. Because the gross sales of satellite tenants will decline, it will become difficult for many of them to pay their rent. Some will vacate, and others will have to be evicted. This may result in uncollected rents, greater vacancies, eviction expenses, and leasing commissions. These damages will usually accrue over a several-year period as the center slowly transforms.
In addition, leases often provide for an award of attorneys' fees to the successful party. In extreme cases, the owner may even be able to seek punitive damages. This may be possible where there has been a breach of the duty of good faith and fair dealing(55) or where third parties have been injured by the anchor's departure. In such cases, the court may find that compensatory damages are not sufficient to deter this type of conduct.(56)
The lesson to learn from this hodge-podge of legal principles is to stay clear of such disputes. The primary safeguard from the owner's point of view is a comprehensive lease that specifically requires the tenant to operate a designated type of business throughout the term of the lease. Without such a provision, the final outcome of ensuing litigation is difficult to predict.
As far as the judiciary is concerned, more consistency is needed. Precedent should be cited in decisions and either distinguished or followed. Moreover, courts need to recognize the difference between a satellite tenant's breach of an ICCO and a similar breach by an anchor tenant.
An anchor's departure may cripple both a shopping center and the satellite tenants who relied on the anchor's presence for their very survival. But if an ICCO is not present, no recourse is available-regardless of the damage.
1. Hornwood , Smith, Food King, 772 P. 2d 1284 N, 1989).
2. "Overages" are sometimes called "percentage rent.'
3. For example, Brown v. Safeway Stores, Inc., 617 P. 2d 704, 710 (Wn. 1980).
4. In Fox , Fox Valley Trotting Club, 134 N.E. 2d 806 (111 1956), the court had no reluctance inholding that a tenant had breached the lease where the lease required the premises to be used for a clearly stated purpose.
5. Edmonds of Fresno MacDonald Group, Ltd., 217 Cal. Rptr. 375 (Cal. App. 1985).
6. The rules which govern implied covenants have been summarized as follows: (1) The implication must arise from the language used or it must be indispensable to effectuate the intention of the parties; (2) it must appear from the language used that it was so clearly within the contemplation of the parties that they deemed it unnecessary to press it; 3) implied covenants can only be justified on the grounds of legal necessity; (4) a promise can be implied only whee it can be rightfully assumed that it would have been made if attention had been called to it; (5) the, can be no implied covenant where the subject is completely covered by the contract'" Cousins Inv. Co. v. Hastings Clothing Co., 113 P. 2d 878, 882 (Cal. App. 1941).
7. EMRO Makting C,. Piemmons, 855 P 2d 528 (8th Cir. 1988).
8. Geardi v. Vaal, 523 N.E. 2d 1327 (111. App. 1988).
9. Wilson v. Cost Plus, 375 So. 2d 683 L,. App. 1979).
10. Borgen v. Wiglesworth, 369 P. 2d 360 (Kan. 1%2).
11. Rapid Associates v. Shopko Stores, Inc., 292 N.W. 2d 668 (Wis. App. 1980). A similar result was reached in Stemmier v. Moon jewelry Company, 139 So. 2d 150, 151 (Fla. App. 1962), where the lease provided that the premises were leased for the sole uninterrupted us, and occupation of said premise, by the lessee for the operation of a retail jewelry store. . . ." See also Cestwood Plaza, Inc. v. Koger Co., 540 S.W. 2d 93 (Mo. App. 1974); Borgen v. Wiglesworth, 369 P. 2d 360 (Kan. 1%2).
12. Baro, Brothers, Inc. v. National Bank of south Dakota, 255 NW 2d 300 (S.D. 1%9).
13. Kroger Company v. Chemical Securities Co., 526 SW 2d 46 (Tenn. 1975).
14. Carter v. Safway, 744 P. 2d 458 (Az. App. 1987).
15. Kroger Company v. Bonny Corp., 216 S.E. 2d 341 GI. App. 1975).
16. Walgreen Arizona Drug v. Plaza Center Corp., 647P. 2d643 (Az. App. 1982).
17. First American Bank v. Safway Stores, inc., 729 P. 2d 938 (Az. App. 1986); Lippman v. Stors, Roebuck and Co., 280 P. 2d 775 (Cal. 1955).
18. Supra at note 4.
19. EMRO, supra at note 7 A contrary finding a, reached here the base rent and the percentage rent were approximately equal. Monte Corp. Stephens, 324 P. 2d 538 Ok. 1958).
20. One owner was innovative in arguing that the lease contained a, implied covenant against assignability, but that argument fell on deaf ears. Rowe v. Great Atlantic & Pacific Tea Co., Inc., 412 N.Y.S. 2d 827 N.Y. App. 1978).
21. Collia, v. McJunkin, 358 S.E. 2d 242 (W.Va. 1987). Gerardi, supra at note 8; Keystone Square v. Marsh Supermarkets, Inc. (Ind. App. 1984); Kroge, Company v. Chemical Securities Co., supra at note 13; Rapids Associates v. Shopko Stos, Inc,, 292 N.W. 2d 668 (Wis. App. 1980).
23. Fist American Bank, supra at note 17. Compare Brown v. Safeway Store5, inc., 617 P. 2d 704 (Wash. 1980), @here
Safeway was permitted to assign its interest in a lease of premises "for a supermarket" to an Asian specialty tore despite objection, that it could not draw as any customers. Also compare Williams , Safeway Stores, Inc., 424 P. 2d 541 (Kans. 1967), where the court expressly fund that the parties contemplated the premises would be used as a grocery but permitted the tenant to sublet to a shoe store.
24. John Hogan Enteprises, Inc. v. Kellogg, 231 Cal. Rptr. 711 (Cal. App. 1986).
25. Jones v. Andy Griffith Products, Inc., 241 S.E. 2d 140 (N.C. App. 1978). Compare Sandor Development Co. v. Retimeyer, 498 N.W 2d 1020 (Ind. App. 1986), where, the court held that the landlord ha, a duty to mitigate damages which required him to accept a carpet business en though the lease required the tenant to operate a music business. Presumably this duty to mitigate would not adversely affect the owner's right to pursue damages, although it might very well be difficult to prove damages as a result of improper tenant "mix" within the center.
26. lack Frost Sales . Harris Trust & Savings Bank, 433 N.E. 2d (N.J. 1970).
27 First American Bank, supra at note 17; Slidell Investment Co. v. City Products Corp., 202 So. 2d 323 (La. App. 1967).
28. First American, supra at note 17; contra, Kroger Company v. Chemical Securities Co., supra at note 13; Slidell Investment Co., supra at note 26.
29, Rapids Associates, supra at note 11.
30. However one court has held that vacating for three month, until a subtenant as found did not constitute an abandonment. Wilson @ Cost Plus, supra at note 9. See also Foureal Co. z,. National Molding Corp., 334 N.Y.S. 2d N.Y. Civ. Ct. 1973).
31. Professional Building of Eureka , Anita Frocks, 2Cal. Rptr, 914 (Cal. App. 1960).
32. Chicago Title v. Southland Corp., 1443 N.E. 2d 294 (111. 1982); Koger Company , Chemcial Securities, supra at note 13.
33. 706 P 2d 523 Ok. 1985). The lease also appeared to give the tenant the right tenante, and damages were, specified in the lease.
35. In the Matter of Goldblatt, 766 F. 2d 1136 (7th Cir. 1985).
36. Wilson supra at note 9.
37. EMRO Marketing, supra at note 7
38. 164 A. 2d 785 (N.J. App. 1960).
39. 260 A. 2d 841 N.J. 1970).
40. Winrock Enterprises, Inc. v, House of Fabrics, 579 P. 2d 787 (N. M. 1978).
41. Lincoln Tower Corp. V. Richre's Jewelry Co., 12 So. 2d 452 Fl,. 1943).
42. Rapids Associates, supra at note 11.
43, Schniker , Gordon, 732 P. 2d 603 C,. 1987); Williston on Contacts SS1338 at 198.
44. McHenry , Broadfoot, 611 P. 2d 1174 (Or. App. 1980).
45. Washington Trust Bank , Circle K Corp., 546 P. 2d 1249 Wn. App. 1976).
46, Stein v Spainhour, 521 N.E. 2d 641 (111. App. 1988); Si,hawk Cop. , Egler 202 N.E. 2d 49 (111. App. 1964).
47. Fox, supra at note 4.
48. See Houston Explorations v Meredith, 728 P. 2d 437 (N, 1986).
49. Monte Corp., supra at note 19.
50. 643 P. 2d 1079 Id. App. 1982).
51. 518 N.E. 2d 564 (Oh. App. 1986).
52. Downtown Associates, Ltd. Burrows Bros. C,., 518 N.E. 2d 546 (Ohio A pp. 1986).
53. Evans, Inc. v. Tiffany & Co., 416 h Supp. 224 (N.D. 111, 1976); Shactman v Masters-Lake Success Inc , 222 N.Y.S. 2d 171 N.Y. App. 1961).
54. Generally, the measure of damages for permanent injury to land is a difference in market value of the Ind immediately before and immediately aft,, the injury. Ault v Dubois, 739 P. 2d 1117 (Ut. App. 1987); Atlas Co,struction Co,.v Slater, 746 P. 2,d 352 (Wy. 1987).
55. See Nicholso, . United Pacific Ins. Co., 710 P. 2d 342 Mont. 1985).
57, See Midwest Supply, Inc. v Waters, 510 P. 2d 876 N,. 1973).
Albert G. Marquis is a partner in the Las Vegas law firm of Marquis Haney & Aurbach, He devotes the majority of his time to business consultation and civil litigation, with emphasis on contract, construction, personal injury, and insurance cases.
Mr Marquis is a member of the board of governors of the Nevada Trial Lawyers Association (NTLA), has served as the editor of the NTLA Advocate, and has written and spoken extensively on construction and insurance issues. He received his law degree from the University of Washington School of Law, where he was an editor of the Law Review
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|Author:||Marquis, Albert G.|
|Publication:||Journal of Property Management|
|Date:||Jul 1, 1990|
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