American Coal Terminal, Inc. v. Midcap Funding Xvii Trust

CourtCourt of Appeals of Kentucky
DecidedAugust 30, 2024
Docket2023-CA-0068
StatusPublished

This text of American Coal Terminal, Inc. v. Midcap Funding Xvii Trust (American Coal Terminal, Inc. v. Midcap Funding Xvii Trust) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Coal Terminal, Inc. v. Midcap Funding Xvii Trust, (Ky. Ct. App. 2024).

Opinion

RENDERED: AUGUST 30, 2024; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0068-MR

AMERICAN COAL TERMINAL, INC.; SNR RAILOPS LLC; SNR RIVER OPS LLC; AND STELLA NATURAL RESOURCES, INC. APPELLANTS

APPEAL FROM BOYD CIRCUIT COURT v. HONORABLE GEORGE DAVIS, JUDGE ACTION NO. 22-CI-00412

ETERA, LLC; BOYD COUNTY, KENTUCKY; COMMONWEALTH OF KENTUCKY, DEPARTMENT OF REVENUE; COMMONWEALTH OF KENTUCKY, ENERGY AND ENVIROMENT CABINET; DYING EMBER COAL COMPANY LLC; KENTUCKY REVENUE CABINET; MID SOUTH CAPITAL PARTNERS, LP; ROGER W. HALL; AND TRIMBLE COAL SALES, LLC APPELLEES

AND

NO. 2023-CA-0250-MR AMERICAN COAL TERMINAL, INC.; SNR RAILOPS LLC; SNR RIVER OPS LLC; AND STELLA NATURAL RESOURCES, INC. APPELLANTS

APPEAL FROM BOYD CIRCUIT COURT v. HONORABLE GEORGE DAVIS, JUDGE ACTION NO. 22-CI-00412

ETERA, LLC; BOYD COUNTY, KENTUCKY; COMMONWEALTH OF KENTUCKY, DEPARTMENT OF REVENUE; COMMONWEALTH OF KENTUCKY, ENERGY AND ENVIRONMENT CABINET; DYING EMBER COAL COMPANY LLC; KENTUCKY REVENUE CABINET; MID SOUTH CAPITAL PARTNERS, LP; ROGER W. HALL, BOYD COUNTY MASTER COMMISSIONER; AND TRIMBLE COAL SALES, LLC APPELLEES

OPINION AND ORDER REVERSING AND REMANDING APPEAL NO. 2023-CA-0068-MR; AND DISMISSING APPEAL NO. 2023-CA-0250-MR

** ** ** ** **

BEFORE: LAMBERT, MCNEILL, AND TAYLOR, JUDGES.

LAMBERT, JUDGE: The above-captioned appellants separately appeal two

summary judgments of the Boyd Circuit Court relating to a breach of contract and

-2- foreclosure action filed against them by MidCap Funding XVII Trust (“MidCap”).

Their first appeal, No. 2023-CA-0068-MR, is of a monetary judgment and order of

sale. Their second appeal, No. 2023-CA-0250-MR, is of an in rem summary

judgment relating to ad valorem tax liens. Upon review and as detailed below, we

reverse and remand with respect to Appeal No. 2023-CA-0068-MR; and we

dismiss with respect to Appeal No. 2023-CA-0250-MR.

I. APPEAL NO. 2023-CA-0068-MR

This appeal involves two promissory notes that were both secured by

real property and personal property, and the consequences that followed when the

holder of the notes chose to conduct a nonjudicial sale of the personal property to

satisfy the outstanding balances of the notes before securing a judicial order

authorizing it to sell the real property. In a summary judgment favoring the holder,

the circuit court determined the holder’s nonjudicial sale of the personal property

to satisfy the outstanding balance of those notes, and admitted receipt of

approximately $1.6 million yielded from that sale to satisfy the outstanding

balance of those notes, were irrelevant to: (1) the judgment amount it was required

to award the holder representing the outstanding balance of those notes; or (2) the

holder’s right to sell the remaining security, i.e., the real property, to satisfy the

outstanding balance of those notes. As such, the circuit court awarded the holder a

judgment of $11,934,461.77 – the amount the holder claimed was the outstanding

-3- balance of the notes before it sold the debtors’ personal property. Further, it

entered an order permitting the holders to satisfy the entirety of that amount by

selling the debtors’ real property.

Contrary to the circuit court’s understanding, however, the holder’s

nonjudicial sale of the personal property and admitted receipt of funds yielded

from that sale: (1) affected the amount of the judgment the holder was entitled to

receive from the debtor based upon the notes; and (2) potentially negated the

holder’s right to collect anything else from the debtors based upon those notes.

Due to the circuit court’s misapprehension of the law regarding these points, and

its refusal to permit the debtors any opportunity to conduct discovery regarding the

holder’s nonjudicial sale of personal property, we reverse and remand for further

proceedings consistent with what is set forth below.

BACKGROUND

The two promissory notes discussed above have been held by MidCap

since August 28, 2020. During the pendency of this appeal, Etera, LLC, was

substituted for MidCap as party-appellee to these proceedings, but we will

continue to refer to the holder of these promissory notes as “MidCap” for the sake

of simplicity. All references to “MidCap” set forth below are effectively

references to appellee Etera.

-4- The obligors of those notes are the appellants, whom we will

collectively label “SNR.” As indicated, they consist of: American Coal Terminal,

Inc.; Stella Natural Resources, Inc.; SNR River Ops LLC; and SNR RailOps, LLC.

The notes were issued in exchange for loans to SNR that originated in August

2017. The notes have been repeatedly amended since that time and are secured by

SNR’s real and personal properties.

SNR defaulted on its loan obligations in 2021, which ultimately

caused MidCap to accelerate the amounts due and owing under the notes and

demand immediate repayment. SNR failed to make any substantial payments

thereafter. Consequently, MidCap filed a breach of contract action against SNR in

Boyd Circuit Court to collect what remained outstanding. In an affidavit attached

to its subsequent motion for summary judgment, MidCap averred that as of

September 30, 2022, $7,860,102.57 was owed on the first note; $4,074,359.20 was

owed on the second; and that SNR was also liable for MidCap’s collection costs

and associated attorney’s fees.

When MidCap filed its motion for summary judgment on October 27,

2022, it sought: (1) judgment against SNR for the outstanding balance of both

notes ($11,934,461.77), plus interest and attorney’s fees; and (2) relief in the form

of judicial orders permitting it to sell the security for the notes (SNR’s personal

and real property) to satisfy that judgment. Less than a week later, however,

-5- MidCap altered the course of its litigation by informing SNR and all other

interested parties of its intention to satisfy part of the outstanding balances of the

notes by conducting a Uniform Commercial Code (UCC) Article 9 nonjudicial sale

of SNR’s personal property collateral on November 15, 2022, pursuant to

Kentucky Revised Statutes (KRS) 355.9-610 and 355.9-611.

SNR responded with an emergency motion to enjoin MidCap from

conducting the nonjudicial sale. In sum, SNR was concerned with the commercial

reasonableness of MidCap’s proposed nonjudicial sale because, as far as it was

aware, MidCap did not have possession or control of the personal property in

question; no potential bidders or purchasers could have properly examined it; and

MidCap had refused to provide SNR any information regarding MidCap’s

marketing efforts for the sale, how the sale would be conducted, or the information

about the personal property MidCap had disseminated to potential bidders. SNR

also argued that a piecemeal sale of its personal property would yield less value

than if it were sold with its real property.

MidCap filed a response on November 11, 2022. There, it argued it

had sent SNR notice of its proposed nonjudicial sale within a reasonable amount of

time per KRS 355.9-612(2), i.e., after SNR’s default and more than ten days before

the proposed disposition. It also insinuated SNR had effectively waived any

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American Coal Terminal, Inc. v. Midcap Funding Xvii Trust, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-coal-terminal-inc-v-midcap-funding-xvii-trust-kyctapp-2024.