Archive for March, 2025

N.C. Business Court Opinions, March 12, 2025 – March 25, 2025

By: Lauren Schantz

 

Hart v. First Oak Wealth Mgmt., LLC, 2025 NCBC 11 (N.C. Super. Ct. Mar. 14, 2025) (Earp, J.)

Key Terms: summary judgment; accredited investor; (un)registered investment adviser; private equity investments; conflict of interest; regulatory agency investigation; consent order; North Carolina Investment Advisers Act; statute of limitations; discovery rule; fraud; negligent misrepresentation; constructive fraud; fiduciary relationship; nominal damages; civil conspiracy; Fifth Amendment; punitive damages

This action involves a dispute between an accredited investor and his investment advisers. Plaintiff Hart engaged Defendant DWM Advisors, LLC to provide investment advisory services. Defendant Davis was DWM’s sole member-manager and a registered investment adviser. Defendant Abolins was a part-owner and employee of DWM.

Between 2009 and 2014, Hart invested substantial sums in various private equity investments recommended by Davis. Davis—and in some cases, Abolins—directly or indirectly owned and/or managed the entities in which Hart invested. Despite assurances that the investments were performing well, Hart ultimately lost most of the money he invested.

In 2017, some of DWM’s former clients began to file suits against DWM, Davis, and Abolins, and Davis came under regulatory scrutiny. DWM sold its public investment accounts to Defendant First Oak Wealth Management, LLC in early 2017, with Abolins joining the company as an employee and Davis a consultant. Hart agreed to move his investment accounts to First Oak but was not informed that First Oak was not managing his private investments until April 2018.

Over the next few years, both state and federal regulators imposed various consent orders on Davis and First Oak, resulting in (1) Davis being permanently barred from the securities industry in South Carolina; (2) Davis being permanently barred from the securities industry nationwide; and (3) First Oak being penalized by the North Carolina Secretary of State for engaging in an unethical business practice by using Davis as an unregistered investment adviser in violation of the North Carolina Investment Advisers Act (“NCIAA”).

Hart alleged that he was not informed of these violations and, further, that Davis advised him on his private equity investments as late as 2019. Hart ultimately lost most of the money he had invested pursuant to Davis’s advice. Hart initiated this lawsuit in October 2021. Abolins and First Oak both moved for summary judgment on all claims.

Statute of Limitations. Abolins and First Oak argued that the three-year statute of limitations barred Hart’s claims for fraud, negligent misrepresentation, and violation of the NCIAA. Applying the discovery rule, which tolls the statute of limitations until a reasonable person should have discovered the fraud, the Court agreed and dismissed the claims, concluding that Hart knew or should have known of the alleged fraud more than three years before filing suit.

Constructive Fraud. The Court determined that Hart had put forth sufficient evidence from which a jury could conclude that Abolins and First Oak, as Hart’s fiduciaries, deterred him from suspecting or discovering the fraud and benefitted therefrom. As a result, a genuine issue of material fact existed as to when the ten-year statute of limitations for constructive fraud began to run. Abolins and First Oak argued that this claim should be dismissed because Hart did not suffer actual damages as a result of their actions, but the Court also concluded that Hart was entitled to at least nominal damages. Accordingly, the Court denied summary judgment on this claim.

Civil Conspiracy. The Court found that Hart had produced sufficient evidence of an agreement among Davis, Abolins, and First Oak to commit constructive fraud and, thus, support a civil conspiracy claim. The Court further concluded that a reasonable jury could infer from Davis’s invocation of the Fifth Amendment during his deposition that he engaged in such constructive fraud, both individually and as an agent for DWM and First Oak. The Court denied the motions for summary judgment as to this claim.

Punitive Damages. Because Hart could recover punitive damages on a claim for constructive fraud with or without an award of nominal damages, the Court denied Abolins’s and First Oak’s motions with respect to this relief.

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Mayer v. Goldner, 2025 NCBC 12 (N.C. Super. Ct. Mar. 17, 2025) (Conrad, J.)

Key Terms: motion to dismiss; Rule 12(b)(6); minority shareholders; captive insurance company; reinsurance; derivative claims; self-dealing; N.C.G.S. § 55-8-09; arguments not raised in briefs; accounting; punitive damages; remedies

This action involves a dispute among the members of an LLC. Plaintiffs Mayer and Queen and Defendant Goldner are the shareholders of Nominal Defendant Sherbrooke Corporate Ltd., a captive insurance company. Sherbrooke reinsures insurance policies issued by a single carrier that provide coverage for nursing homes owned by Goldner.

Plaintiffs alleged that Goldner’s nursing homes underpaid and then stopped paying their insurance premiums to Sherbrooke. These insurance premiums were the LLC’s only source of income. Plaintiffs allege that Goldner, as the majority shareholder of Sherbrooke, subsequently removed Plaintiffs as directors and officers, seized control of the LLC, halted all of its operations, and misappropriated Sherbrooke’s assets to pay his personal legal expenses.

Plaintiffs asserted the following claims against Goldner: derivative claims for breach of fiduciary duty, constructive fraud, and unjust enrichment; a claim to remove Goldner as a director pursuant to N.C.G.S. § 55-8-09; and claims for an equitable accounting and punitive damages. Goldner moved to dismiss the majority of the Complaint pursuant to Rule 12(b)(6).

Derivative Claims. Goldner sought to dismiss the derivative claims to the extent that they were based on the nonpayment of insurance premiums to Sherbrooke, arguing that Plaintiffs improperly imputed obligations owed by his nursing homes to him. The Court denied the motion, concluding that the Complaint, taken in the light most favorable to Plaintiffs, alleged that Goldner used his dual roles to benefit himself and his nursing homes to the detriment of Sherbrooke.

Removal of Director. Although judicial removal of a director is an extraordinary remedy, the Court concluded that Goldner’s alleged wrongful conduct and the resulting impact on Sherbrooke’s operations and financial viability, as pleaded, supported a claim for removal of Goldner as a director of Sherbrooke under N.C.G.S. § 55-8-09. The Court declined to consider Goldner’s argument, raised for the first time at the hearing, that the alleged wrongful conduct was stale.

Accounting and Punitive Damages. The Court dismissed Plaintiffs’ claims for an accounting and punitive damages without prejudice because they are remedies, not independent causes of action.

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Brown v. TM Northlake Mall, LP, 2025 NCBC 13 (N.C. Super. Ct. Mar. 19, 2025) (Conrad, J.)

Key Terms: motion to dismiss; Rule 12(b)(6); judgment on the pleadings; Rule 12(c); torts; negligence; invitees; criminal acts; third parties; foreseeability; reasonable care

These consolidated actions arise from a random act of violence. A car followed Armani Spencer and Plaintiff Bianca Brown from the parking lot of a restaurant located in the Northlake Commons shopping center to neighboring Northlake Mall. The car pulled up next to them and an unknown assailant shot into their car, killing Spencer and seriously injuring Brown. Spencer’s estate and Brown brought suit against various entities associated with Northlake Commons and Northlake Mall, alleging that they knew about the area’s history of criminal activity and negligently breached their duty to warn patrons and provide adequate security. The owner, manager, and security provider of Northlake Commons separately moved to dismiss the complaints pursuant to Rule 12(b)(6) or Rule 12(c).

The Court observed that, although a possessor of land is generally not liable for the criminal acts of third parties that injure invitees, if the criminal conduct was foreseeable, the landowner has a duty to warn its invitees.

The owner and manager of Northlake Commons argued that Plaintiffs failed to plead a claim for negligence because the criminal activity did not occur on Northlake Commons property. The Court disagreed, concluding that the allegations of the complaints showed that the shooting was the result of a series of events that originated on Northlake Commons property due to the owner’s and manager’s failure to provide adequate security for their customers.

The security provider argued that, pursuant to its contract, it was not obligated to provide security to Northlake Mall or to intervene to stop a violent attack anywhere, including on the Northlake Commons property. The Court rejected both arguments, holding that (1) the security provider may be held liable for negligence in performing its duties related to the Northlake Commons property even if the result of the security provider’s negligence occurred elsewhere, and (2) because the security provider’s contract was not before the Court, only the allegations in the complaints could be considered and they were sufficient to state a claim for the security provider’s negligence.

Accordingly, the Court denied the motions.

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Maven Advantage, Inc. v. Square One Storm Restoration, LLC, 2025 NCBC 14 (N.C. Super. Ct. Mar. 24, 2025) (Davis, J.)

Key Terms: motion to dismiss; Rule 12(b)(6); confidential information; trade secrets; non-solicitation; non-competition; non-disclosure; misappropriation of trade secrets; breach of contract; overbroad; unenforceable; “blue pencil” doctrine; punctuation; formatting; embezzlement

Maven Advantage, Inc. initiated this lawsuit in November 2024, asserting various claims arising from alleged misappropriation and misuse of Maven’s confidential and trade secret information by its former employees (Defendants Couch and Daniels) and their new employer (Defendant Square One Storm Restoration, LLC). Maven employed Defendants Couch and Daniels as sales representatives until their resignation in October 2024. Couch and Daniels had entered into non-solicitation, non-competition, and non-disclosure agreements with Maven. In September 2024, Maven experienced a sharp decline in sales, which Maven alleged was a result of Couch and Daniels diverting clients to their new employer. Defendants moved to dismiss Maven’s claims for misappropriation of trade secrets, breach of contract, and civil embezzlement.

Misappropriation of Trade Secrets. Defendants argued that the Complaint failed to adequately identify Maven’s alleged trade secrets, and the Court agreed, concluding that the allegations were too broad. The Court also concluded that Maven’s allegation that Daniels had attempted to obtain certain information was insufficient to allege misappropriation because it did not allege that he had actually obtained the information (which in any event, was not adequately identified as a trade secret). The Court therefore dismissed the claim.

Breach of Non-Competition Provision. Maven conceded that the non-competition provision in Couch and Daniels’s employment agreements was unenforceable under North Carolina law and the Court dismissed with prejudice Maven’s breach of contract claim to that extent.

Breach of Non-Solicitation Provision. Defendants argued that all three subparts of the non-solicitation provision were overbroad and unenforceable; Maven conceded that the third subpart was overbroad but could be severed from the agreement. Applying the blue pencil doctrine, the Court concluded that, based on the formatting and punctuation used, as well as a provision in the employment agreements that specifically provided for the application of the blue pencil doctrine, the third subpart could be severed from the employment agreement. The Court determined that the remaining two subparts of the non-solicitation provision—which restricted solicitation of customers that Defendants had personal contact with and did business with—were narrowly tailored to protect Maven’s legitimate business interests and denied the motion to that extent.

Breach of Non-Disclosure Provision. The Court concluded that the allegations were sufficient to state a claim for breach of the non-disclosure provision by Couch, but insufficient to state a claim for breach of the same provision by Daniels because the complaint did not allege facts constituting an actual breach of the provision by Daniels. The Court therefore denied the motion as to Couch but granted the motion as to Daniels.

Civil Embezzlement. Maven informed the Court that it no longer intended to proceed on this claim, so the Court dismissed it with prejudice.

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Murphy-Brown, LLC v. ACE Am. Ins. Co., 2025 NCBC Order 16 (N.C. Super. Ct. Mar. 12, 2025) (Davis, J.)

Key Terms: de bene esse deposition; subpoena duces tecum; redactions; discovery; delay; untimely

As summarized here, Plaintiffs originally sued various insurers who provided them with primary and excess insurance coverage, contending that the insurers were obligated to indemnify Plaintiffs for amounts paid to settle certain nuisance actions relating to Plaintiffs’ hog farms and to reimburse Plaintiffs for their defense costs for such underlying lawsuits. Presently before the Court was Defendant’s motion to (1) take the de bene esse deposition of Plaintiff Smithfield Foods, Inc.’s Chief Legal Officer ahead of an April trial date, and (2) obtain unredacted copies of certain related invoices produced in discovery via a subpoena duces tecum.

Before joining Smithfield in 2020, the CLO represented Plaintiffs in the underlying lawsuits. During fact discovery, Defendant ACE American Insurance Company deposed three attorneys, not including the CLO, who had represented Plaintiffs in the underlying lawsuits. Plaintiffs also produced numerous attorney invoices, some of which included redactions for fees associated with certain time entries unrelated to the underlying lawsuits.

Fact discovery ended in January 2021. In October 2024, ACE notified Plaintiffs’ counsel that it intended to seek the CLO’s deposition de bene esse. Three months later, ACE attempted to domesticate and serve a subpoena duces tecum on the CLO in Virginia, where she resided, demanding that she appear for a deposition and produce unredacted copies of the invoices. ACE moved to take the de bene esse deposition of the CLO and to obtain unredacted copies of the attorney invoices in February 2025.

After considering (1) when ACE became aware that the CLO would be unavailable; (2) whether ACE knew what the substance of the CLO’s testimony would be; (3) whether the CLO was “friendly” or “hostile”; and (4) whether allowing the de bene esse deposition would unfairly prejudice Plaintiffs, the Court concluded that ACE was not entitled to take a de bene esse deposition of the CLO. The Court also denied ACE’s request for the production of the unredacted invoices as untimely, noting that ACE did not seek production of the invoices during discovery, instead waiting until just weeks before trial.

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Hedgepeth v. Cornblum, 2025 NCBC Order 17 (N.C. Super. Ct. Mar. 17, 2025) (Robinson, C.J.)

Key Terms: order on designation; amend; N.C.G.S. § 7A-45.4(a)(1); piercing the corporate veil; N.C.G.S. § 7A-45.4(c); N.C.G.S. § 7A-45.4(g); “mandatory” mandatory designation; N.C.G.S. § 7A-45.4(b)(2); Rule 8

As summarized here, the Court previously concluded that this matter was not properly designated as a mandatory complex business case under N.C.G.S. § 7A-45.4(a)(1) for both substantive and procedural reasons. Undeterred, Plaintiff filed an Amended Notice of Designation (“NOD”), again seeking designation pursuant to N.C.G.S. § 7A-45.4(a)(1)—based on the same facts as those included in the original NOD—and additionally seeking designation pursuant to N.C.G.S. § 7A-45.4(b)(2). The Court concluded once again that the matter was not properly designated as a mandatory complex business case.

Designation was procedurally improper because (1) N.C.G.S. § 7A-45.4 does not provide a procedure for amending a NOD; and (2) the NOD must be filed contemporaneously with the complaint, not two months later.

Designation was substantively improper because a veil-piercing allegation, standing alone, is insufficient to support designation under N.C.G.S. § 7A-45.4(a)(1). When a case must be designated pursuant to N.C.G.S. § 7A-45.4(b)(2)—a “mandatory” mandatory complex business case—N.C.G.S. § 7A-45.4(g) permits designation at any time. But to qualify for designation under N.C.G.S. § 7A-45.4(b)(2), the case must first qualify for designation under N.C.G.S. § 7A-45.4(a)(1)–(5) or (8) and, pursuant to Rule 8 of the North Carolina Rules of Civil Procedure, the pleading on which designation is based must state affirmatively that damages exceed $5 million. Neither requirement was met.

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Members of N.C. State Univ.’s 1983 NCAA Men’s Basketball Nat’l Championship Team v. Nat’l Collegiate Athletic Ass’n, 2025 NCBC Order 18 (N.C. Super. Ct. Mar. 25, 2025) (Davis, J.)

Key Terms: motion to stay; N.C. State University; basketball; name, image, and likeness; monopoly; anticompetitive; N.C.G.S. § 1-75.12; substantial injustice; discretion; first-filed rule; choice of forum; litigating matters of local concern;

This case involves the alleged misappropriation of former athletes’ names, images, and likenesses (“NIL”). Twelve former members of N.C. State University’s 1983 NCAA Division I men’s basketball team brought suit against the NCAA, alleging that the NCAA has had a decades-long monopoly over collegiate athletics in North Carolina. Plaintiffs allege that the NCAA has generated billions of dollars in revenue from using Plaintiffs’ NILs without compensating Plaintiffs for their use.

The NCAA moved to stay this action in its entirety pending resolution of Chalmers v. NCAA, a related putative class action brought on behalf of former college athletes nationwide pending in the U.S. District Court for the Southern District of New York. The Chalmers lawsuit was initiated after this action and, while it involves substantively similar issues, none of the Chalmers plaintiffs have a direct connection with this action nor has the class been certified.

The NCAA argued that facing suit in North Carolina will work a “substantial injustice” by forcing the NCAA to litigate similar claims in two forums, running the risk of obtaining contradictory rulings, and resulting in judicial inefficiency. Conversely, Plaintiffs contend that they will suffer “substantial injustice” if this action is stayed in favor of the Chalmers lawsuit.

Whether to grant a stay is within the discretion of the Court. The Court concluded that the following factors all weighed against the entry of a stay: (1) although there was overlap between the attorneys in both actions, there was no (current) overlap between Plaintiffs in this action and the plaintiffs in Chalmers; (2) should the first-filed rule apply, this action was filed before the Chalmers lawsuit; (3) this action involved only North Carolina law; the Chalmers action was based on federal law; (4) Plaintiffs’ choice of forum in their home state was entitled to deference; (5) should a class be certified in Chalmers, the litigation of the resulting class action could significantly delay Plaintiffs’ ability to obtain relief; and (6) North Carolina had a strong interest in litigating North Carolina claims brought by North Carolina residents who attended a North Carolina public university for alleged wrongs committed in this state.

The Court therefore denied the NCAA’s motion to stay.

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Charles Schwab & Co., Inc. v. Marilley, No. 210A24, 2025 N.C. LEXIS 162 (N.C. 2025) (per curiam)

Key Terms: motion to stay; arbitration; affirmed

As summarized here, the Business Court previously entered an order denying, in part, Defendant Peter Marilley’s motion to stay proceedings and compel arbitration because the cross-claims at issue fell outside the scope of the parties’ arbitration agreement. The Supreme Court affirmed.

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Vanguard Pai Lung, LLC v. Moody, No. 15A24, 2025 N.C. LEXIS 150 (N.C. 2025) (Dietz, J.)

Key Terms: JNOV motion; directed verdict motion; waiver of issues; affirmed

Following an adverse jury verdict, Defendants filed several post-trial motions, including a JNOV motion. As summarized here, the Business Court determined that two of the issues raised in the JNOV motion had been waived because they were not raised in Defendants’ earlier motion for a directed verdict. The Business Court also rejected Defendants’ other post-trial arguments on the merits. Defendants appealed.

Adopting the reasoning of a line of Court of Appeals cases, the Supreme Court held that while a movant may not need to state the specific grounds for a directed verdict motion in uncomplicated, single-issue cases where the grounds are obvious, in cases involving multiple defenses and theories of liability, a movant’s failure to expressly state in a directed verdict motion a specific argument or theory that forms a ground for relief waives the issue at both the directed verdict and JNOV stage. Applying this rule to the facts at hand, the Supreme Court affirmed the ruling of the Business Court. Although Defendants challenged Plaintiffs’ conversion and fraud claims at the directed verdict stage, the arguments and issues raised at the JNOV stage were different than those raised earlier. Accordingly, the Business Court was correct in determining that the new arguments and issues were waived. Acknowledging the difficulties with raising all issues at the directed verdict stage in open court during trial, the Supreme Court noted that the best practice in multi-claim, multi-defense cases is to prepare and file a written motion for directed verdict so as to provide the opposing parties and the court with notice of the specific grounds for the motion. The Supreme Court also affirmed the Business Court’s orders on the merits, for the reasons stated in the Business Court’s orders.

 

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The information in this article is not, nor is it intended to be, legal advice. You should

Posted 03/26/25

N.C. Business Court Opinions, February 26, 2025 – March 11, 2025

By: Ashley Oldfield

JT Russell & Sons, Inc. v. Russell, 2025 NCBC 7 (N.C. Super. Ct. Mar. 4, 2025 (Conrad, J.)

Key Terms: Rule 12(b)(6); derivative claims; independent panel; N.C.G.S. § 55-7-44; judicial removal of a director; N.C.G.S. § 55-8-09

As summarized here, this action involves a dispute between two branches of a family regarding their company, JT Russell & Sons. Defendant Jim Russell, a former officer and director of the company, asserted derivative counterclaims against the remaining directors for alleged misuse of company assets, as well as a direct counterclaim to remove them as directors. Upon the request of the company’s board, the Court appointed, pursuant to N.C.G.S. 55-7-44(f), an independent panel to conduct an inquiry into whether the maintenance of the derivative counterclaims was in the best interest of the corporation. Following its investigation, the panel submitted a detailed report regarding its inquiry and concluded that it was not in the company’s best interest to pursue the various derivative counterclaims. Thereafter, the company moved to dismiss the derivative counterclaims and the direct counterclaim for removal of directors.

The Court granted the motion to dismiss the derivative counterclaims. N.C.G.S. § 55-7-44 requires that a court grant a motion to dismiss a derivative proceeding if an independent, court-appointed panel determines in good faith after conducting a reasonable inquiry that the maintenance of the derivative proceeding is not in the best interest of the company. Upon review of the panel’s report, the Court concluded that these elements were satisfied and dismissal was warranted.

However, the Court denied the motion to dismiss the direct counterclaim for removal of directors. N.C.G.S. § 55-8-09 allows a court to remove a director if a shareholder shows that the director engaged in fraudulent or dishonest conduct or gross abuse of authority or discretion with respect to the corporation. Limiting its review solely to the allegations in the counterclaims, the Court concluded that Jim’s allegations that the directors had unlawfully circumvented the bylaws to gain corporate control and had engaged in self-dealing were sufficient to state a claim under the statute.

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Lafayette Vill. Pub, LLC v. Burnham, 2025 NCBC 8 (N.C. Super. Ct. Mar. 4, 2025) (Davis, J.)

Key Terms: Rule 12(b)(6); existence of a fiduciary duty between LLC members; breach of fiduciary duty; constructive fraud; derivative claims; statute of limitations; accounting

This action involves a dispute between members of two LLCs. Two of the members brought suit against the third member, asserting various derivative and individual claims arising from Defendant’s alleged financial mismanagement and self-dealing. Defendant moved under Rule 12(b)(6) to dismiss the derivative and individual claims for breach of fiduciary duty and constructive fraud, as well as the claim for an accounting.

Beginning with the individual breach of fiduciary claims, the Court first concluded that the Complaint did not allege the existence of a de jure fiduciary relationship between Defendant and Plaintiffs based on Defendant’s status as a member, since as a general rule, members do not owe fiduciary duties to each other and there was no operating agreement providing otherwise. Second, the Court concluded that, at best, the complaint alleged that Defendant had exercised more power than he actually possessed over the companies and that the Plaintiffs let him do so, and that this was insufficient to establish a de facto fiduciary relationship. The complaint contained no allegations that Plaintiffs, as members with equal managerial authority, had ever called a managers’ meeting, formally voted against Defendant’s actions, or sought injunctive relief. Since the complaint failed to allege the existence of a fiduciary relationship between the members, the Court dismissed the individual breach of fiduciary duty claims.

The Court also dismissed the individual constructive fraud claims due to the absence of a fiduciary relationship and the complaint’s failure to allege any alternative factual basis for a relationship of trust and confidence between the members.

Turning to the derivative claims, the Court noted that Defendant’s argument that the claims were barred by the three-year statute of limitations was inapplicable to the constructive fraud claim because the statute of limitations for such a claim is ten years. As to the breach of fiduciary duty claim, the Court concluded that it would benefit from a more developed factual record regarding when Plaintiffs had actual or constructive knowledge of Defendant’s alleged wrongful acts. Accordingly, the motion to dismiss the derivative claims was denied without prejudice.

Finally, the Court dismissed Plaintiffs’ claim for an accounting because an accounting is a remedy, not a claim.

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Hengqin Dingsheng Zhirong Equity Inv. Fund (Ltd. P’ship) v. Li, 2025 NCBC 9 (N.C. Super. Ct. Mar. 5, 2025) (Davis, J.)

Key Terms: forum non conveniens; N.C.G.S. 1-75.12; China; motion to dismiss; motion to stay

Plaintiffs, Chinese investors and minority shareholders of a Chinese pharmaceutical research company, filed this action against three of the executives of the company, alleging that the executives improperly enriched themselves at the expense of the Plaintiffs and the company. Defendants moved to dismiss the action pursuant to Rules 12(b)(2) and 12(b)(6), or, alternatively, to stay the action on forum non conveniens grounds.

Upon consideration of the forum non conveniens factors, the Court granted the motion to stay and consequently denied the motion to dismiss as moot. First, the nature of the case, applicable law, and the respective interests of China and North Carolina all weighed strongly in favor of a stay because Chinese law would need to be applied to the case, many of the witnesses and documents would require a Chinese translator, and China had a far greater interest than North Carolina in the litigation because the case involved a dispute between Chinese investors of a Chinese company regarding actions mostly taken in China. Second, the location of witnesses and evidence weighed neither for or against a stay because witnesses and evidence were located both in China and North Carolina. Third, China provided an adequate forum for Plaintiffs to litigate their claims despite the fact that China uses a judge-led inquisitorial system, rather than the adversarial system used in the U.S. Finally, although deference is usually given to a plaintiff’s choice of forum, such deference is diminished when, as here, plaintiffs chose to bring their case outside their home forum.

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Epes Logistics Servs., Inc. v. De Piante, 2025 NCBC 10 (N.C. Super. Ct. Mar. 11, 2025) (Robinson, C.J.)

Key Terms: summary judgment; non-disclosure agreement; non-solicitation agreement; breach of fiduciary duty; breach of contract, ; injunctive relief; aiding and abetting breach of fiduciary duty; tortious interference; UDTPA; civil conspiracy; respondeat superior; declaratory judgment; failure to brief an issue

This case arose from the resignation of three employees from Plaintiff and their alleged access to, and use of, Plaintiff’s confidential information to begin their own competing business. Plaintiff brought suit alleging various claims arising from the Individual Defendant’s alleged breach of their employment agreements with Plaintiff and interference with Plaintiff’s customer relationships. Defendants asserted a counterclaim for a declaratory judgment concerning the enforceability of the non-solicitation covenants in their employment agreements. Both sides moved for summary judgment, in whole or in part.

Breach of Fiduciary Duty. Plaintiff asserted that Defendant De Piante owed it both de jure and de facto fiduciary duties and that Defendant Caron owed it de facto fiduciary duties. Because the parties heavily disputed whether De Piante was an officer of Plaintiff, the Court denied Plaintiff’s motion for summary judgment as it related to De Piante’s de jure fiduciary duty to Plaintiff. However, regarding de facto fiduciary duties, the Court determined that there was no evidence that either De Piante or Caron exercised domination and control over Plaintiff; to the contrary, the evidence showed that both worked in a specific division of Plaintiff and reported to superiors. Accordingly, the Court dismissed the claim to the extent it was based on de facto fiduciary duties.

Breach of Contract. The Court found that Plaintiff had put forth sufficient evidence that would permit a jury to conclude that the Individual Defendants had violated the confidentiality provisions of their employment agreements, including by using Plaintiff’s financial information to obtain financing for their new company. Thus, genuine issues of material fact existed, precluding summary judgment on the breach of contract claim.

Injunctive Relief. Plaintiff sought to permanently enjoin the Individual Defendants from using or disclosing its confidential information. Because the Court had already determined that there was a genuine issue of material fact as to whether the Individual Defendants breached their employment agreements by disclosing confidential information, the Court held that it would be premature to determine whether the requested injunctive relief was warranted and therefore denied Defendants’ motion for summary judgment on this claim.

Aiding and Abetting Breach of Fiduciary Duty. Because North Carolina does not recognize a claim for aiding and abetting breach of fiduciary duty, the Court dismissed this claim.

Tortious Interference with Contracts Claim against Individual Defendants. Defendants sought summary judgment on Plaintiff’s claim that the Individual Defendants had tortiously interfered with each other’s employment agreements and the confidentiality provisions found therein. Since the Court had already determined that genuine issues of material fact existed regarding the enforceability of the agreements, it rejected any argument that the tortious interference claim failed because the agreements were unenforceable. The Court was also satisfied that genuine issues of material fact existed regarding inducement. Thus, the Court denied summary judgment on this claim.

Tortious Interference with Prospective Economic Advantage Claim against Defendants. The Court granted summary judgment in Defendants’ favor on this claim because, although Plaintiff had identified specific customers it contends would have continued to do business with it but for Defendants’ conduct, Plaintiff failed to point to any specific contracts that would have ensued but for Defendants’ conduct, a required element of the claim.

UDTPA. Defendants sought summary judgment on plaintiff’s UDTPA claim arguing that it was precluded by the single market participant exclusion. The Court determined, however, that Plaintiff had forecast sufficient evidence that the alleged conduct supporting the claim involved market participants outside of Plaintiff’s organization and therefore denied the motion for summary judgment.

Civil Conspiracy. Because Defendants’ only argument in favor of summary judgment as to the civil conspiracy claim was that it should be dismissed if all other tort claims were dismissed, and other claims had survived dismissal, the Court denied Defendants’ motion for summary judgment on this claim.

Respondeat Superior against Defendant Noble. Because Defendants did not present any argument in their brief regarding this claim, the Court denied Defendants’ motion for summary judgment on the respondent superior claim.

Declaratory Judgment Counterclaim. Defendants sought summary judgment on their claim for a declaratory judgment that the non-solicitation provisions in their employment agreements were unenforceable. Because Defendants had presented sufficient evidence to support a prima facie case as to this claim and Plaintiff failed to present any argument regarding this claim in its brief in opposition to summary judgment, the Court concluded that no genuine issue of material fact existed and granted summary judgment in Defendants’ favor.

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Jackson v. MH Master Holdings, LLLP, 2025 NCBC Order 15 (N.C. Super. Ct. Feb. 28, 2025) (Earp, J.)

Key Terms: BCR 10.9; public records; work product doctrine; attorney-client privilege; anticipation of litigation; substantial need

As summarized here, the N.C. Attorney General initiated this action against Defendant, alleging that Defendant had violated certain provisions of an asset purchase agreement relating to its acquisition of a hospital system in western North Carolina. In response to Defendant’s Rule 34 document request, Plaintiff withheld or redacted various documents that he identified in a privilege log as relating to legal advice. After complying with BCR 10.9, Defendant filed a motion to compel Plaintiff to produce the documents, which Defendant contends are public records.

Because Plaintiff asserted that the majority of the documents were withheld based on the work product doctrine, the Court began by examining the interplay between the Public Records Act and the work product doctrine. Although the Act defines public record broadly, it also recognizes application of the work product doctrine to public records and incorporates the provisions of Rule 26 regarding the production of trial preparation materials. Under Rule 26(b)(3), documents prepared in anticipation of litigation are subject to the work product doctrine. Here, Defendant argued that the documents at issue were prepared in connection with the negotiation of a contract, not in anticipation of litigation. However, because there was evidence in the record that the Plaintiff anticipated litigation early on in the transaction, the Court determined that an in camera review of the documents was necessary to determine if they were prepared in anticipation of litigation.

Defendant also argued that even if the work product doctrine applied, the documents must still be produced because Defendant had a substantial need for the materials (and couldn’t get equivalent materials elsewhere) since the Attorney General was the only source of information concerning his contemporaneous understanding of potentially ambiguous language in the APA. Plaintiff responded that regardless of Defendant’s “substantial need,” the work product documents were not discoverable because they reflected the mental impressions, conclusions, opinions, and legal theories of Plaintiff’s attorneys. Once again, the Court concluded that an in camera review of the documents was needed to determine this issue.

Accordingly, the Court ordered Plaintiff to provide the documents at issue to the Court for an in camera review.

 

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The information in this article is not, nor is it intended to be, legal advice. You should consult an attorney for advice regarding your individual situation.

Posted 03/11/25