Alan Weinshel v. Southcoast Physicians Group, Inc.

CourtMassachusetts Appeals Court
DecidedApril 13, 2023
Docket22-P-0685
StatusUnpublished

This text of Alan Weinshel v. Southcoast Physicians Group, Inc. (Alan Weinshel v. Southcoast Physicians Group, Inc.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alan Weinshel v. Southcoast Physicians Group, Inc., (Mass. Ct. App. 2023).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

22-P-685

ALAN WEINSHEL

vs.

SOUTHCOAST PHYSICIANS GROUP, INC.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, Alan Weinshel, appeals from the award of

summary judgment to the defendant, Southcoast Physicians Group,

Inc. (SPG), concerning the plaintiff's claim of breach of

contract on a successor liability theory. On appeal, the

plaintiff claims the motion judge erred by finding as a matter

of law that SPG was not a successor-in-interest to New Bedford

Medical Associates, P.C. (NBMA). We affirm.

Discussion. We review the allowance of a motion for

summary judgment de novo. See Williams v. Stewart Health Care

Sys. LLC, 480 Mass. 286, 290 (2018). Summary judgment is

appropriate when there are no genuine issues of material fact,

and the moving party is entitled to a judgment as a matter of

law. See Mass. R. Civ. P. 56 (c), as amended, 436 Mass. 1404

(2002). We view the facts in the light most favorable to the nonmoving party. See Premier Capital, LLC, v. KMZ, Inc., 464

Mass. 467, 474-475 (2012).

This dispute arises from SPG's purchase of NBMA in 2014.

In anticipation of the acquisition, the plaintiff ended his

employment with NBMA and executed a Separation Agreement and

Medical Records Custody Agreement (agreements). Under the

agreements, NBMA would release medical records to the plaintiff

for any patient that elected to be treated by him at his new

practice. The plaintiff claimed the patient records he received

pursuant to the agreements were insufficient and filed suit

against SPG in 2019, claiming SPG was liable as a successor to

NBMA for failing to provide adequate records. The judge found

no basis for successor liability and allowed SPG's motion for

summary judgment.

The plaintiff claims the motion judge erred by determining

that SPG was not a successor-in-interest to NBMA. Our law

generally does not impose a predecessor's liabilities on a

successor unless "(1) the successor expressly or impliedly

assumes liability of the predecessor, (2) the transaction is a

de facto merger or consolidation, (3) the successor is a mere

continuation of the predecessor, or (4) the transaction is a

fraudulent effort to avoid [the] liabilities of the

predecessor." Milliken & Co., v. Duro Textiles, LLC, 451 Mass.

547, 556 (2008), quoting Guzman v. MRM/Elgin, 409 Mass. 563, 566

2 (1991). The plaintiff claims on appeal that SPG should be

liable under the de facto merger exception.1

We consider four factors to determine whether a transaction

was a de facto merger:

"[W]hether (1) there is a continuation of the enterprise of the seller corporation so that there is continuity of management, personnel, physical location, assets, and general business operations; whether (2) there is a continuity of shareholders which results from the purchasing corporation paying for the acquired assets with shares of its own stock, this stock ultimately coming to be held by the shareholders of the seller corporation so that they become a constituent part of the purchasing corporation; whether (3) the seller corporation ceases its ordinary business operations, liquidates, and dissolves as soon as legally and practically possible; and whether (4) the purchasing corporation assumes those obligations of the seller ordinarily necessary for the uninterrupted continuation of normal business operations of the seller corporation."

Cargill, Inc., v. Beaver Coal & Oil Co., 424 Mass. 356, 360

(1997). While no single factor is necessary or sufficient,

courts pay particular attention to the continuation of

management, officers, directors, and shareholders. See id. The

focus of the de facto merger analysis is "whether one company

has become another for the purpose of eliminating its corporate

debt." See Milliken, 451 Mass. at 556.

To establish the first factor, the plaintiff was required

to show that there was continuation of enterprise, mainly

1 The motion judge found none of the other exceptions applicable and the plaintiff raises no claim relative to them on appeal.

3 through continuity of operational management. See Cargill, 424

Mass. at 360. Nine of NBMA's executive leaders, who were also

shareholders, became employees of SPG. However, none of the

NBMA executives retained their management titles or roles at

SPG, except one who transitioned from chief financial officer at

NBMA to director of business operations at SPG. The lack of

continuity of management and direction from the NBMA officers

after the acquisition weighs heavily against the application of

this factor. Contrast Cargill, supra at 360-361 (holding buyer

corporation was successor where employees and managers all

maintained their same positions).

Continuity of personnel, physical location, assets, and

general business operations may also indicate continuation of

enterprise. See Cargill, 424 Mass. at 360. SPG acquired NMBA's

assets, including equipment, phone numbers, name, and patient

medical records, and continued to provide medical services at

NBMA's physical location.2 There was therefore some degree of

operational continuity. See id. at 360-61 (successor company

2 The assets SPG acquired included the patient medical records the plaintiff sought. However, it was undisputed that under the NBMA-SPG Asset Purchase Agreement (APA), NBMA retained its liabilities under any contract not specifically assigned to SPG, including its agreements with the plaintiff. The APA also provided that NBMA would have reasonable access to patient records for seven years after closing. These provisions indicate that although SPG acquired NBMA's patient records, the APA authorized NBMA to retrieve and transfer records to the plaintiff under the agreements.

4 used same name, telephone numbers, trucks, and equipment as

predecessor). However, as the motion judge found, an asset

transfer without continuity of management is more akin to a

corporate acquisition than a merger. See Aldrich v. ADD Inc.,

437 Mass. 213, 219 (2002) ("mere purchase of an asset does not

make the purchaser the 'successor' of the seller, bound by the

seller's contractual obligations with other parties");

Martignetti Grocery Co. v. Alcoholic Beverages Control

Commission, 96 Mass. App. Ct. 729, 734 (2019) (de facto merger

is "in essence a continuation of the predecessor's operations").

This factor is therefore not satisfied.

The second factor, continuity of shareholders, is present

when the purchasing corporation exchanges its own stock as

consideration for the predecessor's assets. See Cargill, 424

Mass. at 360.

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Related

Guzman v. MRM/ELGIN WILLCOX & GIBBS, INC.
567 N.E.2d 929 (Massachusetts Supreme Judicial Court, 1991)
Century Fire & Marine Insurance v. Bank of New England-Bristol County, N.A.
540 N.E.2d 1334 (Massachusetts Supreme Judicial Court, 1989)
Cargill, Inc. v. Beaver Coal & Oil Co.
424 Mass. 356 (Massachusetts Supreme Judicial Court, 1997)
Aldrich v. ADD Inc.
437 Mass. 213 (Massachusetts Supreme Judicial Court, 2002)
Milliken & Co. v. Duro Textiles, LLC
887 N.E.2d 244 (Massachusetts Supreme Judicial Court, 2008)
Premier Capital, LLC v. KMZ, Inc.
984 N.E.2d 286 (Massachusetts Supreme Judicial Court, 2013)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)
Williams v. Steward Health Care Sys., LLC
103 N.E.3d 1192 (Massachusetts Supreme Judicial Court, 2018)

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Alan Weinshel v. Southcoast Physicians Group, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/alan-weinshel-v-southcoast-physicians-group-inc-massappct-2023.