BE Capital Management Fund LP v. Fund.com Inc.

CourtCourt of Chancery of Delaware
DecidedJuly 18, 2024
DocketC.A. No. 12843-VCL
StatusPublished

This text of BE Capital Management Fund LP v. Fund.com Inc. (BE Capital Management Fund LP v. Fund.com Inc.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BE Capital Management Fund LP v. Fund.com Inc., (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

B.E. CAPITAL MANAGEMENT FUND LP, ) ) Petitioner, ) ) v. ) C.A. No. 12843-VCL ) FUND.COM INC., ) ) Respondent. )

MEMORANDUM OPINION ADDRESSING EXCEPTIONS TO SPECIAL MAGISTRATE’S REPORT AND RECOMMENDATION

Date Submitted: May 23, 2024 Date Decided: July 18, 2024

E. Wade Houston, ABRAMS & BAYLISS LLP, Wilmington, Delaware; Special Magistrate.

Richard I.G. Jones, Jr., Harry W. Shenton, IV, Zachary J. Schnapp, BERGER MCDERMOTT LLP, Wilmington, Delaware; Attorneys for Thomas Braziel.

LASTER, V.C. This atypical case does not involve a corporate or commercial dispute between

adversarial litigants. It involves a receivership proceeding for an otherwise defunct

corporation. Those proceeding are usually one-sided, ex parte affairs in which the

proponent of the receivership seeks relief and, if appointed as receiver, carries out

the tasks necessary to fulfill the receivership’s mandate. Rarely does anyone provide

the court with a different view. When issuing rulings in those unilateral proceedings,

the court relies heavily on the good faith of the applicant/receiver and the accuracy

and veracity of the information the court receives.

In this case, the process went off the rails.

From the court’s limited perspective, the initial case for the receivership

seemed (and still seems) sound. And for years, the receivership seemed to be

unfolding well. The court had charged the receiver with liquidating an otherwise

defunct corporation, and the receiver marshalled the company’s assets and addressed

its outstanding claims. When those efforts resulted in the company having positive

value, the receiver moved to terminate the liquidation process so that the company

could continue to operate as a publicly traded investment vehicle. The court approved

the receiver’s request, conditioned on the receiver bringing the corporation into good

standing with the Delaware Secretary of State, becoming current in its securities

filings, and holding a meeting of stockholders to elect a new board of directors.1

1 The court doubts it would make the same ruling today. The receivership in

this case proceeded under Section 226(a)(3) of the Delaware General Corporation Law (the “DGCL”), which contemplates the appointment of a receiver when the corporation “has abandoned its business and has failed within a reasonable time to Years later, the court received a letter from a concerned stockholder. The letter

asserted that the receiver never held the meeting of stockholders that the court

ordered. The letter also asserted that that the receiver had embezzled receivership

funds. The allegations were sufficiently concerning that the court appointed a special

magistrate to investigate what happened and make recommendations on how the

court should proceed.2 The order appointing the special magistrate stressed that “[i]f

there is no substance to the allegations, or if additional proceedings are not

warranted, then the Special [Magistrate] will say so.”3

There was substance to the allegations. After completing his investigation, the

special magistrate prepared a draft report.

The draft report carefully documented what had taken place during the

receivership. Based on those recommended findings, the special magistrate

take steps to dissolve, liquidate or distribute its assets.” 8 Del. C. § 226(a)(3). That section does not authorize a receivership that revives the defunct corporation. In re Forum Mobile, Inc., 270 A.3d 878, 889 (Del. Ch. 2022) (“For a custodian appointed under Section 226(a)(3), therefore, the scope of potential authority is limited to liquidating the affairs of the abandoned corporation and distributing its assets.”). To draw on analogies from bankruptcy, a Section 226(a)(3) receivership is like a Chapter 7 liquidation, not a Chapter 11 reorganization.

2 On July 18, 2023, the Court of Chancery amended its rules to change all

references to “Master in Chancery” to “Magistrate in Chancery,” thereby avoiding potential misunderstandings about a term that many associate with slavery. The Chancery term derives from English court practice and is not associated with slavery. Nevertheless, unless a litigant knew that history, the term could be offensive. The appointment predated that revision. Nevertheless, this decision uses the term “special magistrate.”

3 Dkt. 79 ¶ 4.

2 recommended the court find the receiver had used funds from the receivership for

personal gain. As a remedy, the special magistrate recommended that the court

require the receiver to repay the amounts he took from the corporation. The special

magistrate further recommended that the receiver immediately repay $2,000,726.93

in restitution, believing that the receiver’s liability for those amounts was clear as a

matter of law.

The special magistrate explained that the corporation could have additional

claims for restitution, as well as affirmative claims against the receiver that went

beyond restitution, such as an action for disgorgement of the profits the receiver

generated using the corporation’s funds. To avoid any appearance of conflict, the

special magistrate declined to pursue those additional claims and recommended that

the court appoint a successor receiver who could decide how to proceed. The draft

report also recommended that the receiver show cause why he should not have to pay

the special magistrate’s expenses.

Under this court’s procedures, a party can take exceptions to a draft report.

The receiver did so, presenting a host of exceptions. The special magistrate addressed

them in a final report and a supplemental submission.

A special magistrate’s final report does not constitute a judicial decision. If a

party takes exceptions to the final report, as the receiver did, then a constitutionally

appointed judicial officer must review the report de novo.

To the receiver’s credit, he largely acknowledged the accuracy of the special

magistrate’s recommended factual findings. He also accepted aspects of the special

3 magistrate’s recommended remedy by agreeing to provide restitution and to pay the

costs of the special magistrate’s investigation.

The receiver continues to press four exceptions. First, he disputes the

recommended finding that he acted wrongfully when causing the company to claim a

net operating loss in the amount of $8.725 million on its tax returns. Second, he

asserts that certain statements in the final report improperly draw inferences based

on his invocation of the Fifth Amendment privilege against self-incrimination. Third,

he contends that when evaluating potential bad-faith fee-shifting under the American

Rule, the report’s analysis violated his Sixth Amendment right to a jury trial by

noting that his conduct satisfied the elements for potential crimes. Finally, he claims

that the recommended amount of restitution that he should pay immediately is too

high. Rather than a payment of $2,000,726.93, he proposes a payment of

$1,850,726.93.

This decision reviews the final report de novo. The court overrules the first

exception. After a de novo review of the record, the court agrees that the receiver

lacked a reasonable basis to claim a net operating loss in the amount of $8.725

million.

The court overrules the second exception. The special magistrate cited the

receiver’s invocation of his Fifth Amendment privilege against self-incrimination to

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