Allen Beth Incorporated v. Waste Connections US Inc

District Court, E.D. Arkansas·Decided August 23, 2023·No. 3:22-cv-00059·Unknown

Opinion

Case 3:22-cv-00059-DPM Document 61 Filed 08/23/23 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

ALLEN BETH INCORPORATED PLAINTIFF

v. No. 3:22-cv-59-DPM

WASTE CONNECTIONS US, INC. and WASTE CONNECTIONS OF ARKANSAS, INC. DEFENDANTS ORDER The parties continue to wrestle about whether Allen Beth is the correct plaintiff. The record from the first round, as supplemented by the evidentiary materials added in the current round, makes a few things clear enough. Waste Connections' s predecessor made a contract with "Sharp Office Supply" in Ash Flat. Shelly Johnson signed as an owner. The parties' contract, Doc. 25-1, is appended. The contracting parties did business with each other for more than fifteen years. Allen Beth did not always turn square corners when it came to corporate names, fictitious names, and successors. But Shelly Johnson and her husband, Jeff, have been involved in the business through all these years. Allen Beth's amended complaint provides some of the corporate history. After that pleading was filed, though, there were two more corporate developments. Allen Beth appears to have become "Sharp Office Furniture and Logistics, Inc." Doc. 48-2. Shelly Johnson Case 3:22-cv-00059-DPM Document 61 Filed 08/23/23 Page 2 of 12

is the corporate treasurer, and Jeff Johnson is the president, as he was of Allen Beth. Doc. 48-2; Doc. 56-1. In addition, "Sharp Office Supply, Inc." has been incorporated- by other individuals, but at the same address where this small business has long operated. Doc. 48-1. This is intriguing, for the new entity carries the name of the original plaintiff. Doc.1; Doc. 43 at 6-7. The why behind these two recent twists remains unexplained. Whatever the whole story may be, it does not make any legal difference at this point. On the current record as a whole, Allen Beth has standing, and is the real party in interest in substance, because it made the original contract through an unregistered d/b / a name. Iowa Public Service Co. v. Medicine Bow Coal Co., 556 F.2d 400 (8th Cir. 1977); Fed. R. Civ. P. 17. Any mis-naming issue can be corrected in due course. Waste Connections's motion to dismiss based on the naming and entity issues is denied without prejudice to renewal, if need be, on a more complete record. Waste Connections also asks to end the case now on the merits. This request cannot be resolved on the motion to dismiss. But, in the alternative Waste Connections seeks summary judgment and has stated material facts supported by affidavits. The fighting issue is a notice-and-cure provision in the parties' contract. "Customer shall provide [Waste Connections] with written notice of any problem which it believes constitutes a failure by [Waste Connections] to fully perform

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its obligations under this Agreement. [Waste Connections] will be considered in breach of this Agreement if [Waste Connections] does not cure the problem in ten (10) business days after receiving such notice." Appendix at ,r 9a. Allen Beth did not provide pre-suit notice of any overcharges. This case was filed in state court on 26 January 2022. Waste Connections calculated the alleged overcharges paid by Allen Beth for the five-year period before the suit began, determined that amount (adjusted for inflation) to be $2,698.87, added interest at 6%, and got a total of $2,860.80. On 8 February 2022, Kendrick Ketchum (Waste Connections's district manager for Arkansas) met with Shelly Johnson at the business. Ketchum gave Johnson a check for $3,000.00 (which she accepted but has never cashed), explained what the check covered, and informed her that Waste Connections had reduced Allen Beth's service rate to an amount less than it was in January 2017 and that Waste Connections would not charge Allen Beth the fuel surcharge fee in the future. To Ketchum, Johnson seemed satisfied with Waste Connections' s fix of the alleged overcharges. These are the material facts as stated by Waste Connections. Doc. 48-1. Allen Beth has responded to them with various legal arguments rather than with proof showing some genuine dispute. LOCAL RULE 56.1; Conesco Life Insurance Co. v. Williams, 620 F.3d 902, 909 (8th Cir. 2010). In a footnote, Allen Beth does say it disagrees with

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Waste Connections' s characterization of the conversation between Kendrick Ketchum and Shelly Johnson, as well as whether that exchange and the tender of the $3,000.00 check was a legitimate attempt to cure the breach. Doc. 56 at 11, n.6. This factually unsupported aside does not create a genuine issue of material fact. Conesco, 620 F.3d at 909. Allen Beth also argues that it would be premature to address notice and cure given the lack of discovery on the parties' disputes and communications about the alleged overcharges. But no affidavit or declaration establishing a good reason to defer this issue pending some necessary discovery has been offered. Fed. R. Civ. P. 56(d). The Court takes judicial notice of the calendar: Waste Connections tendered the cure on the ninth business day after receiving notice of the alleged overcharges. Fed. R. Evid. 201. No genuine dispute exists on the material facts about notice and cure. The parties chose Texas law. "This Agreement shall be governed in all respects by the laws of the State of Texas, without giving effect to the conflict of laws rules thereof." Appendix at ,r 10. Their choice was reasonably related to their transaction because Waste Connections' s principal place of business is Texas. And the parties' choice does not offend any public policy of Arkansas's. Arkansas Appliance Distributing Co. v. Tandy Electronics, Inc., 292 Ark. 482, 485, 730 S.W.2d 899, 900 (1987).

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Texas law therefore applies to the deep issue: Is the parties' contractual term about notice and cure a covenant or condition? If the former, then Waste Connections has a claim for damages in the circumstances presented; if the latter, then Allen Beth's lack of notice and Waste Connections' s tendered cure eliminate Allen Beth's claim for breach of the contract. Criswell v. European Crossroads Shopping Center, Ltd., 792 S.W.2d 945, 948-49 (Tex. 1990); C & C Road Construction, Inc. v. Saab Site Contractors, L.P., 574 S.W.3d 576, 586-89 (Tex. App. -El Paso 2019, no pet.). This term 1s a condition. Because they can have harsh consequences, "conditions are not favorites of the law." Criswell, 792 S.W.2d at 948. This provision might indeed work a forfeiture. Waste Connections could point to lack of pre-suit notice and refuse to fix any problem. It could, for example, defend against the overcharges alleged here by saying that Allen Beth had let them slide. Absent lack of notice being excused, Allen Beth's alleged overcharges might stand. RESTATEMENT (SECOND) OF CONTRACTS§ 225. Or this provision might work for good.

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Allen Beth Incorporated v. Waste Connections US Inc, (E.D. Ark. 2023).

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