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When a transfer of property involves an accompanying contract, principles of real property law and contract law seem to come into conflict. In these situations, there is understandable confusion as to which principle should prevail, particularly when interpreting contract clauses that appear to restrain alienation of the property in question. Such conflicts have been most visibly debated in the courts when disputes have involved the interpretation of two types of clauses: due-on-sale clauses in mortgage agreements' and clauses in lease contracts that require a landlord's consent as a prerequisite to the alienation of a leasehold. Congress resolved the due-on-sale clause debate when it passed the Garn-St. Germain Depository Institutions Act of 1982

Withholding Consent to Alienate: If Your Landlord Is in a Bad Mood, Can He Prevent You from Alienating Your Lease?