Barriault v. Barriault

CourtSuperior Court of Maine
DecidedSeptember 4, 2018
DocketCUMbcd-cv-17-39
StatusUnpublished

This text of Barriault v. Barriault (Barriault v. Barriault) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barriault v. Barriault, (Me. Super. Ct. 2018).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, ss. LOCATION: PORTLAND Nos. BCD-CV-17-39 & BCD-CV-17-54

DENNIS BARRIAULT, ) ) Plaintiff, ) ) v. ) ) DENRON, INC., ) ) Defendant. ) ) RONALD F. BARRIAULT., ) COMBINED ORDER ON PENDING ) MOTIONS Plaintiff, ) ) v. ) ) CENTRAL DISTRIBUTORS, INC., et ) al., ) ) Defendants. )

Five motions are pending before the Court in these two consolidated cases, as described in

more detail herein. The Court heard oral argument on all motions on August 1, 2019. Dennis

Barriault was represented by George T. Dilworth, Esq.; Ronald Barriault was represented by Kurt

Olafsen, Esq.; Denron, Inc., was represented by Timothy Bryant, Esq.; Central Distributors, Inc.

was represented by Daniel Nuzzi, Esq. and Stacy Stitham, Esq.; and the Fourth-Generation

Shareholders were represented by Tim Norton, Esq.

BACKGROUND

These consolidated civil actions relate to two brothers, Ronald and Dennis, 1 and the two

corporations they own jointly either in whole or in part (the “Corporation Defendants”). Ronald

and Dennis are the only two shareholders of Denron, and also serve as its only officers as President

1 Ronald and Dennis share the last name “Barriault” and as such are referred to by their first names in this Order.

1 and Treasurer, respectively. Ronald and Dennis are also shareholders in Central Distributors, Inc.

(“CDI”) along with their three adult children; however, Ronald and Dennis are the only two

directors of CDI.2 Litigation commenced in the first instance when Ronald sued Denron to allow

a $400,000 distribution to its two shareholders. Dennis was not apprised of that action and had

previously refused to allow the distribution. Dennis sued Denron in BCD-CV-17-39 for consenting

to judgment in that action and otherwise facilitating the $400,000 transaction, and Ronald

intervened as a party-in-interest. Ronald then sued Dennis and CDI in BCD-CV-17-54 for actions

Dennis allegedly took in relation to that company. Each man has now sued for dissolution of one

company or the other: Dennis for dissolution of Denron, Ronald for dissolution of CDI. However,

it appeared to the Court from the parties’ presentations at oral argument that the parties recognize

the high standard that must be met before a Court has authority to dissolve either entity.

Regardless, the two Defendant Corporations each seek judgment in their favor on the

dissolution counts pled against them on narrower grounds. They argue, essentially, that under the

undisputed facts no one is “in control” of either corporation and therefore the alleged bad acts of

a director of either corporation cannot result in judicial dissolution of the corporation as a matter

of law.

The other three motions are more procedural. CDI seeks to exclude the expert testimony

of Mark Filler, Denron seeks protection from the Court by ordering Dennis to take various actions

and abstain from others, and the so-called “Fourth Generation” of Barriaults—all shareholders of

CDI, and purportedly all responsible for the day-to-day operations of CDI—seek a “remedy other

than dissolution,” specifically, that the Court order CDI to fill a purported third director’s seat with

one of them. The Court considers each motion in turn.

2 The Fourth-Generation Shareholders claim that there is a vacant seat for a third director, and move this Court for an order that CDI fill the seat, as discussed below.

2 DISCUSSION

1. Defendant Corporations’ Motions for Partial Summary Judgment

Both Defendant corporations have moved for summary judgment on Count III of the

respective complaints pleaded against them, which coincidentally both plead one count of judicial

dissolution. The plaintiff in each action alleges “illegal, oppressive[,] or fraudulent” acts on the

part of the directors of the corporation; however, as each plaintiff is in fact a director of each

corporation, it is obviously the other director that they are accusing. See 13-C M.R.S. § 1430(2)(B).

The Defendant Corporations claim that because there is no factual dispute that neither Dennis nor

Ronald is “in control” of either corporation, neither man’s bad acts entitles the other to judicial

dissolution as a matter of law under the statute.

The statute at issue, titled “Grounds for Judicial Dissolution” under Maine’s business

corporation act, provides in relevant part as follows:

A corporation may be dissolved by a judicial dissolution in a proceeding by[] . . . [a] shareholder if it is established that . . . [t]he directors or those in control of the corporation have acted, are acting or will act in a manner that is illegal, oppressive or fraudulent.

13-C M.R.S. § 1430(2)(B). The Defendant Corporations ask this Court to analogize to the

judicial dissolution statute for LLCs, which provides in relevant part as follows:

A limited liability company is dissolved, and its activities must be wound up, upon the occurrence of . . . [o]n application by a member, the entry by the Superior Court of an order dissolving the limited liability company on the grounds that the members in control of the limited liability company have acted, are acting or will act in a manner that is illegal or fraudulent[.]

31 M.R.S. § 1595(1)(E). See also Witham Family, L.P. v. D.B.L. Enters., Inc., No. BCD-

CV-17-32, 2019 Me. Bus. & Consumer LEXIS 5, *3-4 (March 7, 2019) (concluding that

“members in control” means members constituting a majority of interest in the LLC). The

Defendant Corporations’ argument, however, fails for two reasons. First, it ignores the plain text

3 of 13-C M.R.S. § 1430(2)(B). Second, and relatedly, it fails to account for legal differences

between the organization of business corporations and LLCs—differences that the Legislature

incorporated into the two statutory judicial dissolution provisions.

Corporations and LLCs differ in important ways. LLCs are owned by members, which may

also act as managers; however, there is no requirement that a manager be a member, or vice versa.

Corporations have a more formal three-tiered management structure with shareholders, who elect

directors, who appoint officers. The respective dissolution statutes for these business entities

account for this difference: while the LLC dissolution statute speaks of “members in control,” the

corporate dissolution statute speaks of “directors or those in control.” 13-C M.R.S. § 1430(2)(B);

31 M.R.S. § 1595(1)(E) (emphases added). As this Court noted in Witham, the Legislature’s

decision to exclude manager misfeasance as grounds for LLC dissolution seems to have been

deliberate. See Witham Family, L.P, No. BCD-CV-17-32, 2019 Me. Bus. & Consumer LEXIS 5,

*6 n. 1.

On the other hand, with respect to directors of corporations, the Legislature expressly wrote

directors into—rather than out of—the corporate dissolution statute. Separate provisions of the

corporate judicial dissolution statute deal with shareholders, who are much more analogous to

members in the LLC context. See 13-C M.R.S. § 1430(2)(C)-(D). As noted above, in this case it

seems that each Plaintiff shareholder may have a difficult time proving that the other director has

acted, is acting, or will act in a manner that is illegal or fraudulent. However, that is clearly a

factual issue that is unresolved one way or the other in the summary judgment record. Moreover,

there is also a genuine factual dispute as to who, if anyone, is in control of either corporation. The

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