Carol Black v. Dennis Brice

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 29, 2026
Docket25-2069
StatusUnpublished

This text of Carol Black v. Dennis Brice (Carol Black v. Dennis Brice) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carol Black v. Dennis Brice, (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 1 of 14

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-2069

In re: SCHLETTER, INC.,

Debtor.

------------------------------

CAROL BLACK, Plan Administrator of Liquidating Debtor, Schletter, Inc.,

Plaintiff – Appellant,

v.

DENNIS BRICE,

Defendant – Appellee.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Martin K. Reidinger, Chief District Judge. (3:23-cv-00457-MR)

Argued: May 6, 2026 Decided: June 29, 2026

Before WYNN, Circuit Judge, FLOYD, Senior Circuit Judge, and Adam B. ABELSON, United States District Judge for the District of Maryland, sitting by designation.

Affirmed by unpublished opinion. Judge Abelson wrote the opinion, in which Judge Wynn and Judge Floyd joined. USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 2 of 14

Thomas Richard Fawkes, TUCKER ELLIS LLP, Chicago, Illinois, for Appellant. Charles M. Sims, O’HAGAN MEYER PLLC, Richmond, Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

2 USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 3 of 14

ABELSON, District Judge:

Schletter, Inc. (“Schletter”), a wholly-owned subsidiary of Schletter Beteiligungs,

GmbH & Co. KG (“Schletter Germany”), was a manufacturer and distributor of racks for

solar panel systems. Under the leadership of Dennis Brice, its President and CEO, Schletter

developed an upgraded system that Brice believed would be superior to existing systems.

Schletter Germany supported the strategy, but the strategy failed. Schletter was left unable

to deliver on various large contracts, and filed for Chapter 11 bankruptcy. Carol Black,

Schletter’s bankruptcy plan administrator, seeks to recover from Brice personally, alleging

his business decisions breached fiduciary duties that he owed to Schletter—duties that she

seeks to enforce on behalf of Schletter’s creditors based on Schletter later becoming

insolvent. The bankruptcy court granted summary judgment to Brice, which the district

court affirmed, holding that Brice’s relevant fiduciary duties were to Schletter Germany

rather than to the creditors of its wholly-owned subsidiary, that Black did not have a valid

claim for a breach of the duty of oversight against Brice, and that the business judgment

rule shielded Brice from liability. For the reasons provided below, we affirm the decision

of the district court.

I.

As discussed more fully below, the facts are viewed in the light most favorable to

Black, the non-moving party. Sedar v. Reston Town Ctr. Prop., LLC, 988 F.3d 756, 761

(4th Cir. 2021). But in advancing her arguments, Black may not rely on the allegations in

her complaint, Fed. R. Civ. P. 56(e), which is what she has largely attempted to do, see

Appellant’s brief at 9–14 (citing the amended complaint as factual support). The district

3 USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 4 of 14

court previously admonished Black about this practice. In re Schletter, Inc., Case No. 3:23-

cv-00457-MR, 2025 WL 2229568, at *2 n.3 (W.D.N.C. Aug. 5, 2025) (“In her appellant

brief before this Court, and her memorandum in response to the Defendant’s Motion for

Summary Judgment before the Bankruptcy Court, the Plaintiff heavily cites to her

Amended Complaint. Any cites to the Complaint are allegations, not evidence. The Court

will not consider any such allegations at the summary judgment stage of this case.”) (record

citations omitted). Thus, the facts below are largely taken from the evidence supplied by

Brice, but viewed in the light most favorable to Black.

Schletter, a supplier of solar panel rack systems, was incorporated in Delaware and

was a subsidiary of Schletter Germany. When Schletter filed for bankruptcy in April 2018,

Schletter Germany owned 95% of Schletter’s common stock, with the other 5% authorized

but unowned and in Schletter Germany’s treasury. 1

Schletter employed Brice as its President and CEO from May 16, 2014 to June 27,

2017. Brice reported to Schletter Germany’s board of directors and was “subject to the

control” of the board and various agreements between the parent and subsidiary. J.A. 1062.

Schletter sold a solar racking system called FS Uno that had been developed by

Schletter Germany. In 2016, Schletter, under Brice’s direction, decided to adapt the FS

Uno system to make it cheaper, lighter, and easier to install. Schletter called the revised

1 The undisputed evidence in the record establishes that Schletter’s previous CEO owned the remaining 5% of the Schletter stock until he was replaced by Brice in 2014, at which time Schletter Germany re-acquired those shares and placed them into its treasury, where they remained during all times relevant to Black’s claims.

4 USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 5 of 14

system G-Max. In October 2016, after about six months of analysis and investigation, Brice

and other members of Schletter’s executive team presented a G-Max “proof of concept” to

Schletter Germany’s board of directors, a presentation that included a discussion of the

potential challenges and risks associated with the project. Schletter Germany’s board

authorized Brice to proceed with the development of G-Max. During the rollout of the G-

Max project, Brice and the leadership team discussed the inherent risks associated with the

project as well as its design, testing, engineering, and manufacturing requirements. Brice

also investigated the terms of the relevant contracts and whether they would be profitable.

The G-Max project team met at least weekly to discuss the project’s progress and Brice

attended some of those meetings, where he was updated regularly on the status of the

project and the risks associated with it. Brice also kept the Schletter Germany board of

directors apprised of the progress of the G-Max project, the anticipated costs of the project,

and made clear that Schletter would be delivering G-Max to its customers before

conducting field testing.

Under Brice’s leadership, however, “the G-Max’s development, production, and

launch all failed” because Schletter could not meet “promised ambitious delivery dates,”

subjecting Schletter to “substantial liquidated damages provisions.” Schletter, 2025 WL

2229568, at *3. Brice also had not initiated “any testing on the G-Max, which further

complicated the production process and caused [Schletter] to underestimate (1) the cost of

the G-Max, (2) [Schletter’s] capacity to produce the G-Max, and (3) how difficult it would

be for customers to install the G-Max.” Id. Brice’s employment was terminated for cause

on June 27, 2017, but he was not given any specific reason for the termination.

5 USCA4 Appeal: 25-2069 Doc: 41 Filed: 06/29/2026 Pg: 6 of 14

Schletter filed for Chapter 11 bankruptcy in April 2018. Id. On October 22, 2020,

Schletter filed this adversary proceeding against Brice (and others, the claims against

whom were later dismissed). Id. After discovery, Brice moved for summary judgment,

which the bankruptcy court granted after a hearing. Id. The bankruptcy court held that Brice

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