Bennett v. Bennett

2019 NCBC 18
CourtNorth Carolina Business Court
DecidedMarch 15, 2019
Docket18-CVS-48
StatusPublished

This text of 2019 NCBC 18 (Bennett v. Bennett) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennett v. Bennett, 2019 NCBC 18 (N.C. Super. Ct. 2019).

Opinion

Bennett v. Bennett, 2019 NCBC 18.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION FORSYTH COUNTY 18 CVS 48

BERT L. BENNETT III and TERRY BENNETT ALLEN,

Plaintiffs,

v.

GRAHAM F. BENNETT; ANN ORDER AND OPINION ON BENNETT-PHILLIPS; JAMES H. MOTION TO DISMISS SECOND BENNETT; and LOUISE BENNETT, AMENDED COMPLAINT

Defendants,

and

BENNETT LINVILLE FARM, LLC; JOHN J. BENNETT; and JEANNE R. BENNETT,

Nominal Defendants.

1. This case arises out of a dispute between siblings, all of whom are members

or former members of Bennett Linville Farm, LLC (“Bennett Farm”). Formed as an

estate-planning vehicle, Bennett Farm’s initial members included most of the

Bennett family—both parents and six of their children. The family’s intent, according

to Plaintiffs, was for each of Bennett Farm’s members to have an equal say in its

affairs.

2. Instead, Plaintiffs contend, they have been denied a voice on nearly every

company decision in recent years. In this action, they allege that three of the Bennett

siblings—Graham Bennett, Ann Bennett-Phillips, and Jim Bennett—conspired to seize managerial authority without the other members’ knowledge or approval. The

three then fraudulently amended Bennett Farm’s operating agreement to consolidate

their control and, having done so, began taking actions on the company’s behalf

without member approval. Plaintiffs now claim that Graham, Ann, and Jim breached

a fiduciary duty owed to the other members, seek declarations that their actions were

unauthorized and invalid, and request a decree judicially dissolving Bennett Farm.

3. In response, Graham, Ann, and Jim seek to dismiss this action in its

entirety. They contend that Plaintiffs lack standing to bring many of the asserted

claims as direct claims, rather than as derivative claims on behalf of Bennett Farm.

They also contend that Plaintiffs fail to state any claim upon which relief can be

granted. For the reasons stated below, the Court GRANTS in part and DENIES in

part the motion.

Fitzgerald Litigation, by Andrew L. Fitzgerald, Lee Denton, and D. Stuart Punger, for Plaintiffs.

Bell, Davis & Pitt, P.A., by Allison B. Parker and Kevin G. Williams, for Defendants Graham F. Bennett, Ann Bennett-Phillips, James H. Bennett, and Bennett Linville Farm, LLC.

Roberson Haworth & Reese, PLLC, by Andrew D. Irby, for Defendant Louise Bennett.

No counsel appeared for Nominal Defendants John J. Bennett and Jeanne R. Bennett.

Conrad, Judge. I. BACKGROUND1

4. The history of this case begins nearly 40 years ago with Bert Bennett, Jr.,

his wife Lillian Bennett, and their eight children: Bert III, Graham, Joy, John, Louise,

Terry, Ann, and Jim. (Second Am. Compl. ¶ 12, ECF No. 25 [“Compl.”].) In the early

1980s, the Bennett parents began giving real estate to their children. (Compl. ¶ 14.)

Over the course of several years, each of the Bennett children received a one-eighth

undivided interest in several parcels in Avery County—a tract that eventually grew

to hundreds of acres. (Compl. ¶¶ 14, 15.)

5. Such was the status quo until 2001, when Joy gave up her interest in the

property, transferring it to her seven siblings. (Compl. ¶ 16.) Around the same time,

John and his wife, Jeanne, requested that they be given a portion of the property to

own separate and apart from the others. (Compl. ¶ 17.) The Bennett parents agreed,

and the other Bennett children deeded their interests in a 35-acre tract to John and

Jeanne. (Compl. ¶ 19.) Although somewhat unclear, it appears that John in return

gave up his interest in the rest of the Avery County property. (See Compl. ¶ 20.)

6. The second amended complaint says little about how the Bennett family

managed the jointly held property at first. The Bennett parents, though having given

the property to their children, seem to have exercised continued decision-making

authority for a time. (See Compl. ¶¶ 18, 24.) That changed in 2007 with the creation

of Bennett Farm, a limited liability company formed to facilitate the parents’ estate

1 This summary is drawn from relevant allegations in the second amended complaint and the

attached exhibits. It is intended only to provide context for the Court’s decision and does not constitute findings of fact. planning. (See Compl. ¶ 24.) The founding members of Bennett Farm were the

Bennett parents (each with a 23% interest), along with Bert III, Graham, Louise,

Terry, Ann, and Jim (each with a 9% interest). (Compl. ¶ 24; see also Ex. 2 at

Schedule I [“Op. Agr.”].) All of the members transferred their ownership interests in

the Avery County property to Bennett Farm. (Compl. ¶ 28.)

7. According to Bert III and Terry (the plaintiffs here), the family intended

Bennett Farm to be a member-managed LLC. (Compl. ¶ 24.) They allege, though,

that Graham and Ann designated Bennett Farm as a manager-managed LLC—

without the knowledge of the other members—in certain Articles of Incorporation.2

(Compl. ¶ 25.) The company’s Operating Agreement was then executed in February

2007. (Compl. ¶ 26.) It also states that Bennett Farm “shall be managed by the

Managers,” a term defined as “those individuals set forth in Schedule II” or

individuals “who are elected to act as Managers.” (Op. Agr. §§ 2.1, 12.1(p).) As

executed, though, the Operating Agreement included no Schedule II, and no election

of managers ever took place. (See Compl. ¶¶ 26, 27.) Bert III and Terry allege that

a document labeled as Schedule II, which lists Graham and Ann as managers, was

added later without the approval of Bennett Farm’s members. (Compl. ¶ 26.)

8. In 2010, Graham and Ann, joined by Jim, amended the Operating

Agreement, again without the others’ knowledge, to include new terms designed to

consolidate their control. (See Compl. ¶ 30.) Among other changes, the Amended

Operating Agreement designates Jim as a third manager, authorizes the managers

2 It is unclear why Articles of Incorporation were adopted for Bennett Farm, which is a limited

liability company and not a corporation. to make capital calls without member consent, loosens the restrictions on a member’s

right to transfer his or her interest, and permits Bennett Farm to redeem any

member’s interest upon the consent of members owning at least 75% of the company.

(See Compl. Ex. 4 §§ 7.2, 9.2, 9.6 [“Am. Op. Agr.”].) Bert III and Terry signed the

Amended Operating Agreement but allege that they were never provided a copy of

the document apart from the signature page, that the terms were never disclosed,

and that Graham falsely represented that their signatures were needed for

administrative purposes. (Compl. ¶ 31.) They saw the new terms for the first time

more than five years later. (See Compl. ¶ 33.)

9. In 2012, Lillian Bennett died. (Compl. ¶ 34.) She passed her interest in

Bennett Farm to Bert III, Graham, Louise, Terry, Ann, and Jim—the six children

with membership interests in the company. (Compl. ¶ 34.) Bert Bennett, Jr., though

still living, did the same a few months later. (Compl. ¶ 35.) Thus, as of June 2012,

Bennett Farm had six remaining members, all with equal interests. (Compl. ¶ 36.)

10. Not long after, Graham, Ann, and Jim asked John and Jeanne to give

Bennett Farm a right of first refusal on their separate 35-acre tract. (Compl. ¶ 37.)

John and Jeanne agreed. (Compl. ¶ 38.) When John later learned that the right of

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Bluebook (online)
2019 NCBC 18, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-bennett-ncbizct-2019.