Coastal Oil New England, Inc. v. Citizens Fuels Corp.

644 N.E.2d 258, 38 Mass. App. Ct. 26, 1995 Mass. App. LEXIS 8
CourtMassachusetts Appeals Court
DecidedJanuary 6, 1995
DocketNo. 93-P-367
StatusPublished
Cited by12 cases

This text of 644 N.E.2d 258 (Coastal Oil New England, Inc. v. Citizens Fuels Corp.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coastal Oil New England, Inc. v. Citizens Fuels Corp., 644 N.E.2d 258, 38 Mass. App. Ct. 26, 1995 Mass. App. LEXIS 8 (Mass. Ct. App. 1995).

Opinion

Laurence, J.

A judge of the Superior Court correctly held that a debtor’s transfer of all its assets without proper advance notice to creditors had violated the Bulk Transfers Act, G. L. c. 106, §§ 6-101 et seq. She ruled, however, that the violation did not give rise to a cause of action by a complaining creditor against the transferee. Her rationale was that the transferee had subsequently sold those assets to a bona fide purchaser. We disagree with that conclusion on the instant facts and, accordingly, reverse and remand.

We derive the pertinent facts from the judge’s unchallenged findings and the parties’ stipulation. The plaintiff, Coastal Oil New England, Inc. (Coastal), is a wholesale supplier of petroleum products. For thirteen years prior to August, 1989, Coastal had done business with Beaver Coal and Oil Co., Inc. (Beaver), a retail seller of home heating oil and related products. Beaver also sold and serviced air conditioning and heating systems. Coastal had always dealt with Beaver through Beaver’s sole officer, director, and shareholder, Michael Viano. As a result of the long and satisfactory relationship, Coastal had provided Beaver with a $200,000 line of credit.

The origin of this litigation was Viano’s August 1, 1989, sale of the assets and business of Beaver to Citizens Fuels Corporation (Citizens) for $1,105,393.71.2 At the time of the sale, Beaver was indebted to Coastal for $222,945.45. The sale included Beaver’s customer list, service parts and equipment, service supplies, trademarks and names, contracts, agreements and leases, automotive equipment and motor vehicles, and books and records. Beaver had sold off its heating oil inventory in the ordinary course of business prior to the sale, so no oil was transferred. Citizens did not assume any of the prior debts, obligations, or liabilities of Beaver. On December 14, 1990, Citizens resold the original Beaver assets to Supreme Fuel Co. (Supreme).

Sometime in the late winter or early spring of 1989, Coastal’s credit manager, John Coughlin, had telephoned [28]*28Viano regarding Beaver’s sizeable overdue account. During the conversation Viano had mentioned to Coughlin that he was contemplating selling Beaver. In late July, 1989, about one week prior to the sale, Coughlin again called to inquire about payment of Beaver’s outstanding indebtedness to Coastal. He was informed by an unidentified Beaver employee that Beaver was going to be sold. The employee did not name the buyer or specify the date of the closing. Coughlin left a message for Viano to call him. Viano finally called, a week later on August 1, 1989, one-half hour prior to the closing. Although Viano then informed Coughlin of the imminent closing, it was too late for Coastal to take any reactive measures. On August 4, 1989, Coastal received a written notice of the transfer from Citizens, by facsimile, which was purportedly sent in compliance with the Bulk Transfers Act and required Coastal to file any claims by August 5, 1989. Coastal did so.

Following the transfer, Coastal received several checks drawn on Beaver’s account in partial payment of Beaver’s outstanding debt, which reduced the balance to $140,552.99. When further payment of that balance was not forthcoming, Coastal commenced suit against Beaver and Citizens (as well as others not relevant to this appeal) on February 28, 1990. Coastal asserted a right to recover because it had not received the advance notice of the sale of Beaver’s assets to Citizens that the Bulk Transfers Act (the Act), codified in art. 6 of our Uniform Commercial Code, G. L. c. 106, required to be sent to creditors. A default judgment was entered against an assetless and judgment-proof Beaver.

Following a bench trial, the Superior Court judge ruled that Citizens had certainly violated the ten-day advance notice provisions of the Act, found in G. L. c. 106, §§ 6-105 & 106. Nonetheless, she held that Citizens was not liable to Coastal because it had subsequently transferred the Beaver assets to Supreme, a supposed purchaser for value and in good faith. The judge concluded that the Act as promulgated [29]*29in Massachusetts afforded no remedy to Coastal in such a situation.3

Coastal’s appeal challenges as erroneous the judge’s rulings that Coastal had no remedy against Citizens and that there was no fraud or intent to conceal the transfer on the part of Citizens or Beaver. Coastal also assigns error to the judge’s denial of its posttrial motion to conform the pleadings to the evidence in order to add counts alleging a fraudulent conveyance and a violation of G. L. c. 93A.

1. The Bulk Transfers Act. The judge concluded that the sale of Beaver’s entire business to Citizens on August 1, 1989, constituted a bulk transfer under G. L. c. 106, § 6-102. She also determined that the notice Citizens had sent Coastal three days after the sale, purportedly in compliance with the Act, violated G. L. c. 106, § 6-105. That section requires that creditors be given notice, either personally or by registered or certified mail, at least ten days prior to a sale qualifying as a bulk transfer. Neither of those rulings is challenged on appeal. The judge further found that there had been no waiver of the notice requirement by Coastal. Citizen’s appellate argument that this finding was erroneous is unconvincing.

Despite the statutory commandment that noncompliance with the notice requirement shall render the transfer “ineffective against any creditor of the transferor,” G. L. c. 106, § 6-105, as inserted by St. 1957, c. 765, § 1, the judge ultimately ruled that Citizens was not liable to Coastal. She [30]*30based this conclusion on her finding that, prior to the commencement of the litigation, Citizens had resold the Beaver assets to a good faith purchaser for value, Supreme, who took title to the assets free from any defects. See G. L. c. 106, § 6-109.4The judge reasoned that, because Massachusetts had not adopted an optional provision of the originally proposed Uniform Commercial Code, § 6-106, the Legislature must not have intended to expose transferees to liability in a case such as this one.5 This result has the effect of sanctioning intentional noncompliance with the Bulk Transfers Act undeterred by the threat of any adverse consequences. Fortunately, the statute is susceptible of a more equitable application in the instant circumstances.

It is true that the only explicit remedial provision mentioned in art. 6 for failure to comply with the notice provision of § 6-105 is that, under § 6-104, the creditor may “disregard the transfer and levy on the goods as still belonging to the transferor.” Comment 2 to Uniform Commercial Code § 6-104, 2C U.L.A. 72 (1991). See also Comment 3 to § 6-[31]*31104, 2C U.L.A. 72 (1991).6 Nowhere, however, does the Act specify that such a levy is the exclusive remedy for noncompliance. The Uniform Commercial Code generally mandates that, “[u]nless displaced by the particular provisions of this chapter, the principles of law and equity . . . shall supplement its provisions.” G. L. c. 106, § 1-103, as inserted by St. 1957, c. 765, § 1. The Massachusetts Code commentators anticipated the supplementation of the remedial provisions of art. 6 in precisely this fashion:

“In neither [§ 6-104 nor § 6-105] . . . are the penalties for noncompliance stated; the transfer is merely said to be ‘ineffective’ ....

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Cite This Page — Counsel Stack

Bluebook (online)
644 N.E.2d 258, 38 Mass. App. Ct. 26, 1995 Mass. App. LEXIS 8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coastal-oil-new-england-inc-v-citizens-fuels-corp-massappct-1995.