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Crown Communication, LLC v. T6 Unison Site Management, LLC

Citations: 138 So. 3d 256; 2014 WL 1778002; 2014 Miss. App. LEXIS 244Docket: No. 2012-CA-01510-COA

Court: Court of Appeals of Mississippi; May 6, 2014; Mississippi; State Appellate Court

Narrative Opinion Summary

This case involves Crown Communications LLC (Crown) and T6 Unison Site Management LLC (Unison) in a dispute over a Lease Agreement originally entered into with Sammie and Nora Ormon. The agreement included a right of first refusal for Crown if the property was sold. After the Ormons' death, their sons assigned the lease rights to Unison, prompting Crown to cease rent payments and claim the assignment triggered its right of first refusal. Unison filed for breach of contract, leading to cross-motions for summary judgment. The circuit court granted summary judgment to Unison, ruling the assignment did not transfer fee title, only an interest, and required Crown to deposit overdue rent into the court's registry. Crown's appeal was dismissed due to the order not being final under Mississippi Rule of Civil Procedure 54(b) since it lacked certification and did not resolve all claims. As a result, the appeal was deemed interlocutory, leaving Crown liable for costs and obliged to pay the past-due rent into court.

Legal Issues Addressed

Finality of Judgment under Mississippi Rule of Civil Procedure 54(b)

Application: The court determined that the order granting summary judgment to Unison was not final and appealable because it did not resolve all claims against all parties and lacked Rule 54(b) certification.

Reasoning: The circuit court's order regarding the case involving multiple parties and claims was examined for finality and appealability under Mississippi Rule of Civil Procedure 54(b).

Interlocutory Order and Appeal Dismissal

Application: Without certification as final under Rule 54(b), the order granting summary judgment to Unison was interlocutory, leading to the dismissal of Crown's appeal.

Reasoning: Consequently, since the order did not resolve all claims against all parties and lacked the necessary Rule 54(b) certification, the appeal was dismissed for lack of jurisdiction.

Right of First Refusal in Lease Agreements

Application: Crown argued that the Assignment of the Lease by the Ormons to Unison triggered its right of first refusal, asserting that it equated to a conveyance of property interest.

Reasoning: Crown counterclaimed, asserting that the Assignment triggered the right of first refusal clause due to an alleged conveyance of property interest to Unison.

Summary Judgment Standards

Application: The Circuit Court granted summary judgment to Unison after determining that the Ormons only assigned an interest in the property, not the fee title, thus dismissing Crown's claim.

Reasoning: On August 14, 2012, the court granted summary judgment to Unison, determining that the Ormons only assigned an interest in the property, not fee title.