With no explanation, chose the best option from "A", "B", "C" or "D". was not a substantial amount. Id. Thus, the court determined that the lease contained an implied covenant of continued use. In reaching its conclusion, the Eighth Circuit declined to follow applicable Mis souri law as set forth in Crestwood Plaza, Inc. v. Kroger, 520 S.W.2d 93 (Mo.App. E.D.1974). In that case, this Court held that the mere fact that a rental provision of a lease was based upon a combination of a fixed rent and a percentage rent is insufficient to find an implied covenant of continued use. Crestwood Plaza, Inc., 520 S.W.2d at 97; see also EMRO, 855 F.2d at 531 (McMillian, J., dissenting). In fact, Missouri courts consistently refuse to find implied covenants in clearly drafted leases. See Halls Ferry Investments, Inc. v. Smith, 985 S.W.2d 848, 852-53 (Mo.App. E.D.1998) (<HOLDING>); Michigan Sporting Goods Distributors, Inc. v.

A: recognizing implied covenant to market gas
B: holding language of lease did not indicate implied covenant of continued use
C: holding that in the employment context cause of action seeking tort remedies for breach of implied covenant is not permitted recovery for breach of this covenant is limited to contract remedies
D: holding that where a commercial lease requires landlords consent before assigning the lease or subletting the leased premises implied covenant prohibited landlord from withholding consent unreasonably
B.