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Seatrain Lines, Inc. v. Interpool Ltd. (In re Seatrain Lines, Inc.)

Citations: 19 B.R. 929; 1982 Bankr. LEXIS 4195Docket: Bankruptcy Nos. 81 B 10311 (EJR), 81 B 11059; Adv. Nos. 81-5652-A, 81-5653-A

Court: District Court, S.D. New York; May 5, 1982; Federal District Court

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The motion for partial summary judgment by Seatrain Lines, Inc. against Interpool Limited regarding its second, fourth, and sixth claims is denied. Seatrain filed a Chapter 11 bankruptcy petition on February 11, 1981, and, as a debtor in possession, seeks a declaration of ownership over certain container units, claiming they were purchased from Interpool for $4,900,000, with an upfront payment of $1,000,000 for 2,000 containers. Seatrain asserts ownership free of any liens, while Interpool argues the sale agreement was effectively a loan and that a prior Consent Order from December 15, 1981, allows Interpool to reclaim the containers. Interpool's counterclaims include set-offs for amounts owed by Seatrain. The court finds that material facts are in dispute, as indicated by the existence of triable issues, and therefore, summary judgment is inappropriate. The court must favor the party opposing the motion when doubts about material facts arise.

The Consent Order and sale agreement are critical to resolving this matter, raising factual and legal issues, particularly regarding the intent of the parties involved. Summary judgment is not suitable when the intent is ambiguous, specifically whether the sale agreement was intended as a loan or a lease, which necessitates an evidentiary hearing. Additionally, clarification is needed on whether the Schedule A containers fall under the Consent Order's provisions; if they do not, ownership remains a contested issue. Significant factual and legal questions related to both the Consent Order and sale agreement must be addressed prior to any final determination. Furthermore, it is unclear whether Seatrain's complaint presents multiple claims or a single claim with various causes of action; if it is a single claim, partial summary judgment cannot be granted. The presence of factual and legal disputes necessitates a full hearing to resolve the matter. Consequently, the debtor’s motion for partial summary judgment is denied. The case involves two actions: one by Seatrain and another by its subsidiary, Ocean Container Equipment, S.A., with both seeking partial summary judgment on their respective complaints, which will be treated collectively as the Seatrain complaint and motion.