Central Fidelity Bank v. Goode

30 Va. Cir. 521, 1990 Va. Cir. LEXIS 438
CourtLynchburg County Circuit Court
DecidedDecember 13, 1990
StatusPublished

This text of 30 Va. Cir. 521 (Central Fidelity Bank v. Goode) is published on Counsel Stack Legal Research, covering Lynchburg County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Central Fidelity Bank v. Goode, 30 Va. Cir. 521, 1990 Va. Cir. LEXIS 438 (Va. Super. Ct. 1990).

Opinion

BY JUDGE RICHARD S. MILLER

In the captioned cases, I will dismiss both the bill of complaint and the cross-bill for the reasons herein stated. I also rule that the applicable statute of limitations to Central Fidelity Bank’s claim to be five years under Code § 8.01-243(B).

Central Fidelity Bank's Claim Against Lewis B. Goode, Jr.

A. The Statute of Limitations

Whether the one-year limitation period of § 8.01-248 or the five-year limitation period of § 8.01-243(B) applies to a claim such as Central Fidelity Bank’s has not been decided in Virginia. No case law in any jurisdiction was found concerning estate administration fees as a corporate opportunity. No Virginia case was found specifically referring to the term “corporate opportunity.” However, illustrative of the fact that “injury to property,” as that term is used within § 8.01-243(B), contemplates injury to more than just real or personal property can be seen in the holding in Lavery v. Automation Manage-[522]*522merit Consultants, Inc., 234 Va. 145, 360 S.E.2d 336 (1987), where the Supreme Court of Virginia, in considering the tort of unauthorized use of a consultant's name for trade purposes, held that the plaintiff had stated a claim for injury to property and that the five-year limitation applied, rather than the one-year limitation, citing Worrie v. Boze, 198 Va. 533, 95 S.E.2d 192 (1956), which involved injury to the expectation of future business patronage.

A close reading of Sensenbrenner v. Rust, Orling & Neale, 236 Va. 419, 374 S.E.2d 55 (1988), cited by Goode's counsel, shows that the plaintiff's claim in that case was a contract claim, not a tort claim for injury to property, which makes it distinguishable from the case at bar.

In the captioned case, Central Fidelity Bank’s claim sounds in tort, and I stand by the Court’s previous ruling that its claim is for damage to property and that the five-year limitation applies.

B. Corporate Opportunity

On the issue of burden of proof, I rule that Central Fidelity Bank must prove its claim that Goode was a fiduciary and that he took a position inconsistent with the interests of Central Fidelity Bank by a preponderance of the evidence. Once this should be proven, the burden of proof would then be on Goode to overcome this by clear and convincing evidence. See Creasy v. Henderson, 210 Va. 744, 749, 173 S.E.2d 823 (1970), where the Supreme Court of Virginia used the term “clear and satisfactory.” This means, “more than a mere preponderance of the evidence.” See Creasy at p. 750.

A corporate opportunity is a business opportunity in which a corporation has an expectancy, property interest, or right, or which in fairness should otherwise belong to the corporation. Black's Law Dictionary 340 (6th Ed. 1990). It exists “when a proposed activity is reasonably incident to the corporation’s present or prospective business and is one in which the corporation has a capacity to engage." 3 W. Fletcher, Cyclopedia of the Law of Private Corporations, § 861.1 at 285 (1986).

One of the earlier and leading cases discussing a corporate official’s usurping a corporate opportunity is Guth v. Loft, Inc., 23 Del. Ch. 255, 5 A.2d 500 (1939). The Guth case, supra, “has been cited as precedent in almost every corporate opportunity opinion handed down since it was decided in 1939, no matter which rule the court adopts.” See, [523]*523Walker, Legal Handles Used To Open or Close The Corporate Opportunity Door, 56 Nw. U. L. Rev. 608, 617 (1961).

The Guth court stated:

[I]f there is presented to a corporate officer or director a business opportunity which the corporation is financially able to undertake, is, from its nature, in the line of the corporation’s business and is of practical advantage to it, is one in which the corporation has an interest or a reasonable expectancy, and, by embracing the opportunity, the self-interest of the officer or director will be brought into conflict with that of his corporation, the law will not permit him to seize the opportunity for himself. At 511.

Courts frequently use the “fairness” test to determine the existence of a corporate opportunity by applying ethical standards of what is equitable under the circumstances, so that if it has been determined that the appropriated opportunity is within the corporation’s “business expectations,” then the “fairness” test is utilized to determine whether the corporate officer violated his fiduciary duty by pursuing the opportunity. The “degree of likelihood of realization from the opportunity is the key to whether an expectancy is tangible” and thus a corporate opportunity. 3 Fletcher § 861.1 at 285.

In the case of Hofheimer v. Seaboard Citizens National Bank, 154 Va. 392, 153 S.E. 656 (1930), rehearing opinion, 154 Va. 896, 156 S.E. 581 (1931), cert. denied, 238 U.S. 855 (1931), it was stated:

The designation in a will of one as executor does not confer a property right upon the person so designated. However precious may be the mark of confidence bestowed by such nomination, it does not amount to property. There is nothing tangible about it. Nothing vests in a person so nominated by the mere execution of the will... The will is ambulatory and may be changed, revoked or cancelled by the maker at any time during his life. 154 Va. at 399 (Emphasis added).

There is no question that Central Fidelity Bank has shown by a preponderance of the evidence that Central Fidelity Bank, through its trust department, was and is in the business of handling decedents’ estates. It also has shown that Cy Eichelbaum was one of its customers much earlier than in 1987 and that he had a will naming Central Fidelity Bank as his personal representative. However, in the present [524]*524case, I find that Cy Eichelbaum in 1987 and again in 1988 exercised his unilateral right to nominate his own personal representative so as to designate someone other than Central Fidelity Bank, and therefore, any corporate opportunity which Central Fidelity Bank may have had was virtually terminated. See, Orchard v. Covelli, 590 F. Supp. 1548 (E.D. Pa. 1984). I further find from the evidence that this change was initiated and made solely by Mr. Eichelbaum without any urging or influence by Goode. To die contrary, the unrebutted evidence is that Goode urged Eichelbaum not to change Central Fidelity Bank as his nominated personal representative. In support of this and in addition to Goode's testimony, see the testimony of Katherine Eichelbaum, Robert Eichelbaum and Kenneth S. White concerning Mr. Eichelbaum’s decision not to nominate the bank and to select someone else. The evidence is that Eichelbaum would have selected another person to be his personal representative if Goode would not do so. See Transcript, p. 217, line 14, through p. 219, line 1.

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Related

E. I. duPont deNemours & Co. v. Universal Moulded Products Corp.
62 S.E.2d 233 (Supreme Court of Virginia, 1950)
Glass v. Glass
321 S.E.2d 69 (Supreme Court of Virginia, 1984)
Creasy v. Hicks Henderson
173 S.E.2d 823 (Supreme Court of Virginia, 1970)
Branch v. Virginia Employment Commission & Virginia Chemical Co.
249 S.E.2d 180 (Supreme Court of Virginia, 1978)
Chaves v. Johnson
335 S.E.2d 97 (Supreme Court of Virginia, 1985)
Duggin v. Adams
360 S.E.2d 832 (Supreme Court of Virginia, 1987)
Lavery v. Automation Management Consultants, Inc.
360 S.E.2d 336 (Supreme Court of Virginia, 1987)
Worrie v. Boze
95 S.E.2d 192 (Supreme Court of Virginia, 1956)
Sensenbrenner v. Rust, Orling & Neale, Architects, Inc.
374 S.E.2d 55 (Supreme Court of Virginia, 1988)
Orchard v. Covelli
590 F. Supp. 1548 (W.D. Pennsylvania, 1984)
Guth v. Loft, Inc.
5 A.2d 503 (Supreme Court of Delaware, 1939)
Hofheimer v. Seaboard Citizens National Bank
153 S.E. 656 (Supreme Court of Virginia, 1930)
Hofheimer v. Seaboard Citizens' National Bank
156 S.E. 581 (Supreme Court of Virginia, 1931)

Cite This Page — Counsel Stack

Bluebook (online)
30 Va. Cir. 521, 1990 Va. Cir. LEXIS 438, Counsel Stack Legal Research, https://law.counselstack.com/opinion/central-fidelity-bank-v-goode-vacclynchburg-1990.