Austin Watterson v. Josh Wilson

CourtMissouri Court of Appeals
DecidedAugust 3, 2021
DocketWD83848
StatusPublished

This text of Austin Watterson v. Josh Wilson (Austin Watterson v. Josh Wilson) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Austin Watterson v. Josh Wilson, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Western District

AUSTIN WATTERSON, ) Appellant, ) WD83848 v. ) ) JOSH WILSON, et al., ) FILED: August 3, 2021 Respondents. )

APPEAL FROM THE CIRCUIT COURT OF CASS COUNTY THE HONORABLE WILLIAM B. COLLINS, JUDGE

BEFORE DIVISION ONE: ALOK AHUJA, PRESIDING JUDGE, LISA WHITE HARDWICK AND ANTHONY REX GABBERT, JUDGES

Austin Watterson appeals from the circuit court’s grant of summary

judgment against him in a civil lawsuit concerning ownership of a business.

Watterson contends that the circuit court erred in granting summary judgment

because the record contains genuine disputes of material facts. For reasons

explained herein, we affirm the judgment in part and reverse in part.

FACTUAL AND PROCEDURAL HISTORY

Sometime prior to July 2011, Watterson and Josh Wilson, along with a third

party, Mike West, entered into an arrangement in which they worked together

under the limited liability company (“LLC”) Wilson Home Development (“WHD”).

The terms of the arrangement are in dispute. Watterson contends he was a part owner of WHD, while Wilson contends that Watterson was merely an employee.

Watterson’s name did not appear in WHD’s articles of organization.

In May 2011, Watterson filed for bankruptcy under Chapter 7 of the United

States Code. In his petition to the bankruptcy court, Watterson did not claim any

ownership interest in an LLC. Watterson alleged that on August 1, 2011, he and

Wilson met at Wilson’s home to discuss their business relationship. Watterson

alleged that, during this conversation, the pair orally agreed to start a new LLC

which they would manage together, without West, as equal co-owners.

Watterson further alleged that the pair agreed to split profits and losses equally

and agreed that Wilson would manage the company’s finances while Watterson

would manage sales. The agreement was never reduced to writing. Articles of

organization for Wilson Home Restoration (“WHR”) were filed in December 2011,

and listed Wilson as “the organizer.”.

Wilson and Watterson worked together under WHR until 2014, when Wilson

unilaterally terminated Watterson’s relationship with the LLC. Watterson testified

that, per their oral agreement, the two acted as equal co-owners of WHR while

working together. Wilson admitted that, at least once while working together and

in his presence, Watterson held himself out publicly as a co-owner, which Wilson

never corrected at that time or any time thereafter. Additionally, the pair

appeared as guests on a radio show, where Wilson admitted that he “heard or

understood” that “perhaps . . . something on the radio may have alluded to” he

2 and Watterson acting as co-owners of WHR. Wilson contends that Watterson was

merely an employee.

Watterson filed suit against Wilson alleging he was wrongfully ousted from

WHR without receiving the value of his ownership interest in the company. After

discovery, the circuit court granted Wilson’s summary judgment motion on

Watterson’s claims of constructive trust, promissory estoppel, fraud, breach of

contract, and quasi-contract and quantum meruit. Watterson appeals.

STANDARD OF REVIEW

“When considering appeals from summary judgments, [we] will review the

record in the light most favorable to the party against whom judgment was

entered.” ITT Commercial Finance Corp. v. Mid-America Marine Supply Corp.,

854 S.W.2d 371, 376 (Mo. banc 1993). “Facts set forth by affidavit or otherwise in

support of a party's motion are taken as true unless contradicted by the non-

moving party's response to the summary judgment motion.” Id. “We accord the

non-movant the benefit of all reasonable inferences from the record.” Id. “Our

review is essentially de novo.” Id.

ANALYSIS

We must first address whether judicial estoppel applies to preclude

Watterson from alleging an interest in WHR. Wilson argued judicial estoppel

below, but the circuit court did not specify whether it granted summary judgment

on the basis of judicial estoppel or on each of Watterson’s claims individually.

Thus, we must discuss each in turn. Watterson contends that judicial estoppel 3 does not preclude him from asserting ownership of WHR. “Judicial estoppel will

lie to prevent litigants from taking a position, under oath, ‘in one judicial

proceeding, thereby obtaining benefits from that position in that instance and

later, in a second proceeding, taking a contrary position in order to obtain benefits

. . . at that time.’” In re Contest of Primary Election Candidacy of Fletcher, 337

S.W.3d 137, 140 (Mo. App. 2011) (quoting State Bd. of Accountancy v. Integrated

Fin. Solutions, L.L.C., 256 S.W.3d 48, 54 (Mo. banc 2008)). To determine if judicial

estoppel applies, we consider the following factors:

First, a party's later position must be clearly inconsistent with its earlier position. Second, courts regularly inquire whether the party has succeeded in persuading a court to accept that party's earlier position . . . . A third consideration is whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.

Id. “[U]nder United States Supreme Court precedent these factors are not fixed

or inflexible prerequisites.” Id.

The parties dispute whether Watterson’s failure to claim an ownership

interest in WHD and WHR during his prior bankruptcy proceeding precludes him

from alleging the interest now. Watterson filed for bankruptcy in May 2011. He

testified that he and Wilson agreed to become co-owners of the soon-to-be

organized WHR in August 2011. Therefore, Watterson asserts that, when he filed

his bankruptcy petition, he did not have any interest in WHR to disclose to the

bankruptcy court. Further, Watterson filed under Chapter 7 of the United States

4 Code, which does not require parties to apprise the court of any property interests

acquired after the filing date. Harris v. Veigalahn, 575 U.S. 510, 513-14 (2015).

Wilson argues that Watterson should have listed an interest in WHR

because it was sufficiently rooted in the pre-bankruptcy past. Property acquired

after filing the bankruptcy petition may still be property of the bankruptcy estate if

an interest in that property was “sufficiently rooted in the pre-bankruptcy past.”

Segal v. Rochelle, 382 U.S. 375, 380 (1966). Wilson first argues that WHR was a

continuation of WHD and, therefore, was sufficiently rooted because WHD existed

prior to Wilson’s filing. This argument ignores that WHD and WHR are ultimately

separate and distinct legal entities, and the summary judgment record does not

indicate whether WHR merely continued WHD’s business (in terms of its

customers, employees, assets, or otherwise). To find a sufficiently rooted interest,

courts consider whether a “readily discernible interest” existed at the time of

filing. In re Vote, 276 F.3d 1024, 1026-27 (8th Cir.

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Austin Watterson v. Josh Wilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/austin-watterson-v-josh-wilson-moctapp-2021.