Autotech Technologies, LP v. Palmer Drives Controls and Systems, Inc.

CourtDistrict Court, D. Colorado
DecidedJanuary 21, 2025
Docket1:19-cv-00718
StatusUnknown

This text of Autotech Technologies, LP v. Palmer Drives Controls and Systems, Inc. (Autotech Technologies, LP v. Palmer Drives Controls and Systems, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Autotech Technologies, LP v. Palmer Drives Controls and Systems, Inc., (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer

Civil Action No. 19-cv-00718-PAB-NRN

AUTOTECH TEHCNOLOGIES, LP, d/b/a EZAUTOMATION, an Illinois Limited Partnership,

Plaintiff,

v.

PALMER DRIVES CONTROLS AND SYSTEMS, INC., a Colorado Corporation, and LYNN WEBERG,

Defendants.

ORDER

This matter comes before the Court on Plaintiff’s Motion for Attorney Fees and Interest [Docket No. 320]. On June 5, 2024, defendant Palmer Drives Controls and Systems, Inc. (“Palmer”) filed a response. Docket No. 322. I. BACKGROUND Beginning on May 22, 2023, a five-day jury trial took place in this case. Docket No. 298 at 1. At the conclusion of the trial, the jury found in favor of plaintiff Autotech Technologies, LP d/b/a, EZAUTOMATION (“Autotech”). Id. Specifically, the jury found in favor of Autotech on its claims for breach of contract, intentional interference with prospective business relations, and breach of fiduciary duty arising from a confidential relationship, finding that Autotech suffered damages in the amount of $195,000. Docket No. 296 at 1-2. On July 10, 2023, Palmer filed for Chapter 11, Subchapter V, bankruptcy. Docket No. 311. The Court administratively closed this case pending resolution of Palmer’s bankruptcy petition. Docket No. 314 at 2. On May 1, 2024, the Court reopened the case upon the bankruptcy court granting Autotech’s motion for relief from automatic stay so that it could refile its motion for attorneys’ fees. Docket No. 316. In the present motion, Autotech requests $98,039 in attorneys’ fees for having obtained a favorable judgment on its breach of fiduciary duty claim, as well as a

prejudgment interest award of $91,518.97 and a postjudgment interest award amount that is to be determined. Docket No. 320 at 11. Palmer argues that Autotech is not entitled to attorneys’ fees because it does not fall under the breach of trust exception to the American Rule regarding attorneys’ fees. Docket No. 322 at 1–4. Even if Autotech is entitled to attorneys’ fees, Palmer argues that the “$98,039 figure is completely arbitrary and grossly inflated.” Id. at 4. Further, Palmer opposes an award of prejudgment interest because it is not clear whether the damages awarded by the jury were allocated for past, present, or future lost profits. Id. at 4–6. II. ANALYSIS

A. Attorneys’ Fees for Breach of Fiduciary Duty Claim Generally, Colorado follows the American Rule that a prevailing litigant cannot recover an award of attorneys’ fees absent a statute, court rule, or private contract to the contrary.1 Bernhard v. Farmers Ins. Exch., 915 P.2d 1285, 1287 (Colo. 1996). Colorado courts, however, have fashioned an exception to this rule in breach of trust actions where a fiduciary holds funds in trust for the benefit of a party who is ultimately injured by the breach. Heller v. First Nat’l Bank, 657 P.2d 992, 999 (Colo. App. 1982);

1 Both parties assume Colorado law applies to the issue of attorneys’ fees. Moreover, Autotech’s claim for breach of fiduciary duty was brought under Colorado state law. See Docket No. 121 at 13–18, ¶¶ 71–102. Buder v. Sartore, 774 P.2d 1383, 1390 (Colo. 1989). Although the exception to the American Rule originated in breach of trust actions, Colorado courts have extended the doctrine to breach of fiduciary duty actions. See, e.g., In re Estate of Shuler, 981 P.2d 1109, 1113 (Colo. App. 1999) (noting that a beneficiary in a breach of fiduciary duty claim against his or her personal representative may recovery attorneys’ fees, but

declining an attorneys’ fee award); In re Conservatorship of Roth, 804 P.2d 265, 267 (Colo. App. 1990) (successful beneficiary in breach of fiduciary duty action against bank custodian may recover attorneys’ fees). However, the breach of fiduciary duty exception only “broadened the application of the breach of trust exception to breaches of fiduciary duty that are closely analogous to a breach of trust.” In Int. of Delluomo v. Cedarblade, 328 P.3d 291, 294 (Colo. App. 2014). There must be the “type of fund, type of wrong, or type of wrongdoer at issue in Heller and Buder” for the exception to apply and the injured party to be eligible to recover attorneys’ fees. Id. The rationale underlying the breach of duty exception is that an award of

attorneys’ fees in a breach of duty action is necessary to make the injured party whole. Heller, 657 P.2d at 999–1000. As the Colorado Court of Appeals noted in Moore v. Edwards, 111 P.3d 572, 574 (Colo. App. 2005), the ability “to recoup funds misappropriated by a fiduciary through a successful lawsuit would likely be a meaningless exercise to a beneficiary without a rule allowing for an award of attorney fees.” Palmer and Autotech were partners on a project, whereby Palmer introduced the project’s client to one of Autotech’s competitors, whose products the client ultimately used rather than Autotech’s. Docket No. 121 at 3–11, ¶¶ 7–58. The jury found that Palmer breached its fiduciary duty to Autotech arising from a confidential relationship between the Palmer and Autotech. Docket No. 296 at 1. Specifically, the jury found that (1) Autotech had a confidential relationship with Palmer; (2) Autotech justifiably placed trust and confidence in Palmer, or that Palmer invited, accepted, or appeared to accept Autotech’s trust; (3) Palmer assumed a duty to represent Autotech’s interests in

the transaction at issue; (4) Palmer had a duty to represent Autotech’s interests by reason of a confidential relationship; and (5) Palmer violated its duty, causing damage to Autotech. Docket No. 292 at 20–21. In Cedarblade, the defendant was a beneficiary of the plaintiff’s trust. 328 P.3d at 292. The defendant unduly influenced the plaintiff to transfer real property from the trust, resulting in the appointment of a guardian ad litem who sued the defendant on the estate’s behalf for a breach of fiduciary duty. Id. at 292–93. The jury found that the defendant breached her fiduciary duty, stemming from her confidential relationship with the plaintiff. Id. at 293, 296. The appellate court, however, found that the defendant’s

“breach of fiduciary duty stemming from her confidential relationship with [the plaintiff] did not closely resemble a breach of trust.” Id. at 296. In contrast to a “trustee's duty [that] springs from the underlying legal agreement to manage property and is bounded by the scope of that relationship . . . the duty of a confidential relation arises from superiority and influence, is borne by the individual, is not expressly agreed upon, and involves property only incidentally.” Id. Thus, the court reversed the ruling of the trial court that the plaintiff was entitled to attorneys’ fees under the American Rule. Id. at 297 Cedarblade is instructive regarding the facts of this case. Here, the jury found that Palmer violated a fiduciary duty borne out of a confidential relationship. Docket No. 296 at 1. Although Palmer breached its fiduciary duties to Autotech by suggesting the products of one of Autotech’s competitors to the client, Palmer did not violate a “legal agreement to manage property.” See Cedarblade, 328 P.3d at 296. Like the defendant

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Autotech Technologies, LP v. Palmer Drives Controls and Systems, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/autotech-technologies-lp-v-palmer-drives-controls-and-systems-inc-cod-2025.