Keydata v. United States

• Keydata Corporation = "Keydata" = 1st tenant = the holdover tenant
• NASA = the National Aeronautics and Space Administration = 2nd tenant
• Wyman Street Trust = "Wyman" = commercial building proprietor = commercial landlord
• Keydata & NASA leased a space at a building owned by Wyman in Cambridge, Massachusetts
• NASA needed more space in the leased building
• Keydata was looking to move out of the leased building
• NASA agreed to rent Keydata's computer room in the building
• The contract between the 2 tenants (Keydata & NASA) was set forth in a lease contract executed by the commercial landlord (Wyman)
• Keydata would lease the space to NASA starting on January 1st 1969
• NASA agreed to pay Wyman $39,000 for air-conditioning equipment that Keydata had installed in the computer room
• Wyman would then turn around & hand over the 39,000 to Keydata for the AC equipment
• However, Keydata refused to vacate the computer room by January 1st 1969
• The next day, NASA canceled the lease contract because Keydata hadn't vacated
• Also, NASA didn't pay Wyman the $39,000 for the AC equipment

• Keydata sued NASA to collect the $39,000 payment (for the AC equipment) as Wyman's assignee
• Both parties moved for summary judgment

In a lease involving the U.S. government, must the landlord deliver actual possession of the leased premises at the beginning of the lease term (January 1st 1969)?

What law should apply to a government lease?

• Keydata argued that Wyman only had the right to deliver possession to NASA on January 1st 1969, but no duty to deliver actual possession to NASA.
• Keydata argued that Wyman had fulfilled its obligation as landlord.
• Keydata argued that NASA had illegally rescinded the lease.

In leases involving the U.S. government (in this case NASA), the landlord (Wyman) must deliver actual possession of the leased premises at the beginning of the actual lease term (January 1st 1969).

Summary judgment in favor of NASA