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United Unions, Inc. v. Webster & Sheffield

Citations: 521 A.2d 273; 1987 D.C. App. LEXIS 289Docket: No. 84-779

Court: District of Columbia Court of Appeals; February 23, 1987; District Of Columbia; State Supreme Court

Narrative Opinion Summary

In this case, an office building owner appealed a judgment awarding damages to a tenant who claimed the landlord unreasonably withheld consent for a sublease. The lease stipulated that subleasing required the landlord's prior written consent, which could not be unreasonably withheld. The tenant, having requested permission to sublease and received no timely response, proceeded under the assumption of implied consent. The landlord later refused consent, citing a firm policy against subleasing. The trial court found in favor of the tenant, awarding damages based on the difference between the tenant's lease obligations and potential sublease income. On appeal, the landlord argued that the trial court erred by not having the jury specifically address the reasonableness of the consent refusal. However, the appellate court affirmed the trial court's judgment, finding that the existing jury instructions were adequate to cover the issues. The court noted that the landlord did not evaluate the subtenant's suitability, and the withholding of consent was deemed unreasonable. The decision, supported by legal precedent, resulted in affirming the tenant's damages award.

Legal Issues Addressed

Jury Instructions and Interrogatories

Application: The appellate court found the jury instructions sufficient to address the issues presented by the evidence, despite the landlord's contention regarding the jury form.

Reasoning: On appeal, the landlord contended that the trial court erred by not including a specific question on the jury form regarding the reasonableness of withholding consent. However, the appellate court found the jury instructions sufficient to address the issues presented by the evidence and thus affirmed the lower court's decision.

Lease Provisions on Subleasing and Consent

Application: The lease allowed subleasing with the landlord's prior written consent, which could not be unreasonably withheld. The tenant argued that the landlord's refusal to consent was unreasonable.

Reasoning: The lease allowed the tenant to sublet with the landlord's prior written consent, which could not be unreasonably withheld.

Reasonableness of Withholding Consent

Application: The jury's conclusion that the landlord's withholding of consent was unreasonable was supported by evidence, including the landlord's failure to evaluate the subtenant's suitability.

Reasoning: The jury's conclusion on the reasonableness of withholding consent was supported by evidence, including the landlord's failure to evaluate the subtenant's suitability.

Tenant's Notice and Landlord's Consent

Application: The jury found that the tenant provided the required notice for subleasing, but the landlord did not exercise the right to release the tenant or consent to the sublease.

Reasoning: The jury found that Webster, Sheffield provided the required notice but that United Unions, Inc. did not exercise its right to release the tenant or consent to the sublease.