Anchel v. Shea

44 Pa. D. & C.4th 144, 1999 Pa. Dist. & Cnty. Dec. LEXIS 52
CourtPennsylvania Court of Common Pleas, Pike County
DecidedDecember 13, 1999
Docketno. 1005-1999-Civil
StatusPublished

This text of 44 Pa. D. & C.4th 144 (Anchel v. Shea) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Pike County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anchel v. Shea, 44 Pa. D. & C.4th 144, 1999 Pa. Dist. & Cnty. Dec. LEXIS 52 (Pa. Super. Ct. 1999).

Opinion

THOMSON, P.J.,

This opinion is entered to address the petitions for preliminary injunction filed by both parties in the above-captioned matters. A hearing was held on November 22,1999. The court is acting pursuant to its authority as a court of equity or chancery as related to the supervision and control of corporations. 15 Pa.C.S. §104 and 15 Pa.C.S. §1793.

BACKGROUND

These findings and conclusions are preliminary in nature, are based upon the record before the court, and are mainly limited to the facts necessary for the determination of the present injunctive requests. As a matter of comment, the court is surprised that the corporate documents rely upon the “significant transactions” provisions [146]*146(located in three locations) for issues related to the executive employment of a controlling shareholder, who would seemingly have wanted to more explicitly protect his position; further, it is astounding that resolutions of import would not be recorded in the form of minutes, and that notice provisions for the holding of meetings where the control of the company is at issue would not be scrupulously followed. These facts, showing a certain disregard to the formalisms of corporate activity, belie a weakness on the part of the request for equitable action. When the issue of irreparable harm to the corporation is raised, the harm really befalls the shareholders ... the vast majority of whom are responsible for the very problems of loose drafting, poor record keeping, and devious tactics which have presented this situation. Were it not for uninvolved shareholders and innocent employees, the court may have seen fit to allow the litigation to go forth without injunctive action while the participants continue to foul their own nests.

All of the arguments presented aside, the court finds the whole idea that a person with the control of a majority of shares cannot maintain a simple board majority which will continue to support him to be quite suspect (except in the case of a for cause removal, which this is not). The only way this would seem possible, would be through a certain amount of either treachery by directors or inattention by the executive which prevents the executive from knowing the true activities and intentions of the board and its members. In other words, even if only a simple majority is required to remove the CEO who controls a share majority, with enough notice, he should be able to elect a majority of directors whose judgment would allow for his retention.

[147]*147Truly an odd case it is where there is essentially a claim by a majority shareholder of oppression committed by a minority shareholder. Such is a case where the victim may deserve his fate. Anchel may bargain away the contractual safeguards he has in the ownership and control of the company, and on several occasions it would appear that he has — first with the introduction of outside investors in 1994, and later with the renewal and modification of the employment contract. Further, the retaining of Tommyca Freadman as designee where the other party has required his placement on the board seems like a foolish dilution of one’s own position. A little forethought and attention to the contents of the corporate documents should prevent such a case from coming before the court. Inattention can, and maybe should, be taken advantage of. But failure to follow proper notice procedures, which in itself causes another’s inattention, is unfair, and intolerable under the law. Both sides have tried to act in this manner.

The factual circumstances which are at issue involve: the existence and interpretation of certain provisions found in the documents relating to the relationship of the parties (articles of incorporation, bylaws, shareholders agreement, voting trust, employment agreements and collateral writings); and the corporate actions which occurred on the several occasions. Those occasions are: (1) the board meeting of April 27,1999, where Anchel’s employment contract was renegotiated and extended; (2) the October 26, 1999 meeting, where the purported removal of Anchel as CEO, and the rescission of the voting trust occurred; (3) and the meetings of November 12, 15 and 19 where there were various attempts to re[148]*148constitute the board and undo the actions of the October meeting.

The injunctive orders/decrees herein are made to preserve the status quo of the corporation during the pendency of the action. The “status quo” in this circumstance is a changeable thing, as the corporation must continue to function, and the shareholders must be able to expect the corporation to act in their best interest. The court cannot see the benefit of having the company and its shareholders left without the ability to act and would therefor provide injunctive measures to maintain status which would have existed had the powers of the corporation, its shareholders and its directors been exercised appropriately. The court is constrained, however, to maintain the status quo as it existed immediately prior to the wrongful conduct. See e.g., Lewis v. City of Harrisburg, 158 Pa. Commw. 318, 631 A.2d 807 (1993) and Maritrans GP Inc. v. Pepper, Hamilton & Scheetz, 529 Pa. 241, 602 A.2d 1277 (1992).

The court has done what it can to avoid giving any advantage to either side merely on the basis of timing. The parties have showed their hands, and there is no way to put the parties back into the tactical positions that existed in the days leading up to the October 26,1999 meeting. The advantages of the differing notice requirements for calling meetings of the board and the shareholders have already been gained or lost. The court is now faced with the prospect of determining what valid actions have happened, and maintaining the integrity of the corporation through the current controversy as though it had been properly represented by its directors and shareholders.

[149]*149The issue of bond was not addressed other than the general claims by both parties that the corporation will be harmed if the other is in control. The court must set bond in an amount that will approximate the “reasonably foreseeable” damages which could be wrought by the injunction. See Pa.R.C.P. 1531(b), and see Christo v. Tuscany Inc., 368 Pa. Super. 9, 533 A.2d 461 (1987) and Greene County Citizens United v. Greene County Solid Waste Authority, 161 Pa. Commw. 330, 636 A.2d 1278 (1994). Determining the difference in value of the business judgment of the parties is speculative at best. Both parties in their respective petitions have, of course, suggested a nominal bond. Neither has contested the other’s bond recommendation. The issuance of the injunction is for the purpose of maintaining the value of the corporation as a whole, and represents, in part, granting the petitions of both sides, and a protection of both their interests in the value of the corporation. The parties have in fact agreed that it is in the benefit of all parties that the management of the corporation be clarified during the pendency of the action. Wherefore, only nominal bond shall be required.

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Related

Christo v. Tuscany, Inc.
533 A.2d 461 (Supreme Court of Pennsylvania, 1987)
Maritrans GP Inc. v. Pepper, Hamilton & Scheetz
602 A.2d 1277 (Supreme Court of Pennsylvania, 1992)
Lewis v. City of Harrisburg
631 A.2d 807 (Commonwealth Court of Pennsylvania, 1993)

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Bluebook (online)
44 Pa. D. & C.4th 144, 1999 Pa. Dist. & Cnty. Dec. LEXIS 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anchel-v-shea-pactcomplpike-1999.