Goat Island South Condominium Assoc., Inc. v. IDC Clambakes, Inc. (In re IDC Clambakes, Inc.)

Case Type:
Case Status:
15-1771, 15-1818 (1st Circuit, Mar 24,2017) Published
The Court of Appeals reversed the District Court's Opinion and affirmed the Bankruptcy Court's decision to award no equitable relief to the Associations. Nothing on the Rhode Island Supreme Court opinions granting ownership to the Associations should bear on to grant more relief than the ownership already afforded them. The Court denied the Associations claims for Debtor to pay them for the use and occupancy of the Regatta Club during the claim period.
Procedural context:
On a second appeal after the case being remanded to the bankruptcy court for a determination of whether implied consent for debtor's use and occupancy of the property in controversy also give rise to an implied obligation to pay the fair value for use and occupancy of the property; debtor clambakes argues that the bankruptcy court should not have reached the Associations' arguments about implied in fact contract and unjust enrichment. Further, challenged the District Court's finding of clear error of the bankruptcy court's equitable analysis ordering to pay the Associations $2.6 million for its use and occupancy of the Regatta Club during the claim period. The Associations cross- appealed requesting interests on top of the $2.6 million award and argued that the bankruptcy court erred in awarding no restitutionary relief.
After decisions from the Rhode Island Supreme Court granting ownership of a reserve area and a regatta club to a group of condominium associations, IDC Clambakes, Inc., the lessee of the property in controversy, filed for bankruptcy in 2005. The Associations filed a proof of claim seeking relief for Clambakes alleged trespass on their property between 1998 and April 2005 (the period of the controversy over the ownership of the property). In 2013 the court of appeals affirmed the bankruptcy court's finding that the associations had impliedly consented to Clambake's use an occupancy of the Regatta Club, but remanded on the issue of whether there was an implied obligation to pay for that use and occupancy.
Lynch, Baldock (sitting by designation) and Kayatta

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