Commercial Resins Company Inc. v. Carlson

CourtDistrict Court, N.D. Oklahoma
DecidedJune 8, 2021
Docket4:19-cv-00616
StatusUnknown

This text of Commercial Resins Company Inc. v. Carlson (Commercial Resins Company Inc. v. Carlson) is published on Counsel Stack Legal Research, covering District Court, N.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commercial Resins Company Inc. v. Carlson, (N.D. Okla. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

COMMERCIAL RESINS COMPANY, INC., ) et al., ) ) Plaintiffs, ) ) v. ) Case No. 19-CV-616-JED-CDL ) RON CARLSON, JR., et al., ) ) Defendants. )

OPINION AND ORDER The Court has for its consideration Plaintiff Commercial Resins Company’s motion for preliminary injunction (Doc. 71). CRC asks the Court to enter a “preliminary injunction maintaining the status quo decision of the shareholders of CRC—as well as of outside, independent counsel for CRC—not to advance litigation costs to the Defendants.” (Doc. 71 at 6). As explained further below, such an injunction is unwarranted at this time because CRC has not shown the requisite risk of imminent harm. I. BACKGROUND A. General Background This dispute revolves around the alleged mismanagement of CRC, a family-owned, pipeline-treatment manufacturer that, for most of its 51-year existence, was run by Ron Carlson Sr. Starting in 2005, Defendant Ron Carlson Jr. (referred to herein as Mr. Carlson) took over as president and chief executive. Until recently, he ran the company with his wife, Defendant Christine Carlson, who served as its controller and, according to the plaintiffs, its de facto chief financial officer. Mr. and Ms. Carlson’s tenure at the helm of CRC came to an end in 2019 after the company’s board allegedly discovered that they had misappropriated millions of dollars from the company. Shortly after the missing funds came to light, Mr. Carlson’s brothers and fellow CRC shareholders—Plaintiffs Greg Carlson, Kevin Carlson, and Mark Carlson—voted via a written consent to oust the couple and install a new board. Following the defenestration, Greg Carlson took over as the company’s president.

Strictly speaking, the sibling shareholders merely purport to have fired Ron and Christine Carlson and to have removed Mr. Carlson from his seat on CRC’s board of directors. The legal effect of their votes is disputed. Mr. Carlson alleges in Counterclaims (Doc. 41 at 4–5) that the sibling shareholders lacked the voting power to remove him. According to the Counterclaims, Ron Carlson Sr. executed a Stock Proxy in Mr. Carlson’s favor in 2014 as part of a deal in which Mr. Carlson agreed to take Ron Carlson Sr.’s place as guarantor on $2.5 million in debts owed by CRC.1 Although Ron Carlson Sr. later sold the shares to the siblings, Mr. Carlson claims that the shares remained burdened by the alleged proxy. Thus, according to Mr. Carlson, the siblings own a majority of CRC’s shares, but they do not control a majority of the shareholder votes. Accordingly, he claims,

any actions they purport to have taken on behalf of CRC, including his termination and removal from the board of directors, are without effect. He further alleges that, on February 4, 2020, he was “duly elected” president of the corporation and that he and two others were “duly elected” as CRC’s board of directors. Notwithstanding Mr. Carlson’s claim that he remains legally entitled to control CRC, he seems to concede that his siblings now exercise control of the company for all practical purposes.

1 Although the Counterclaims indicate that a copy of the 2014 Stock Proxy was included as an exhibit, the document was not attached to the Counterclaims. (See Doc. 41 ¶ 15). B. Procedural Background Mr. Carlson did not initially bring his claims in federal court. After CRC brought the instant suit, he filed an Answer, but it made no mention of the alleged 2014 Proxy or his claim to majority share-voter status. Instead, he brought the allegations in a state court suit against his siblings, claiming that they had wrongfully ousted him and then mismanaged the company. See Commercial

Resins Company, Inc. and Ronald Carlson, Jr., v. Gregory Carlson, et al., Case No. CJ-2020-572, Tulsa County District Court, filed February 11, 2020. In addition to Mr. Carlson’s individual and derivative claims, the petition purported to join claims asserted by CRC on its own behalf. Rather than fight these allegations in state court, the siblings moved to dismiss on the grounds that Mr. Carlson was obliged to bring his claims as compulsory counterclaims in the existing federal action. The presiding judge agreed, administratively closing the case pending the outcome of the instant action. The siblings also joined the federal litigation, alleging derivative claims on behalf of CRC and seeking a declaratory judgment determination that Mr. Carlson’s alleged proxy is invalid, leaving them a majority of the voting shares. (See Doc. 32). With his state court claims effectively dismissed, Mr. Carlson imported the allegations into

the federal litigation in the form of Counterclaims. (See Doc. 41). Like the state court petition, the Counterclaims assert causes of action by Mr. Carlson, both as an individual and derivatively on behalf of CRC, as well as by CRC directly. C. CRC’S Advancement Decision CRC’s Bylaws provide for the advancement of fees to a director or officer who is sued for actions taken in his or her capacity as such. Shortly after filing this suit, CRC hired a local law firm to determine whether advancement was appropriate in this case. (See Doc. 71-7). In November 2020, the firm issued a written opinion in its capacity as “outside, independent legal counsel.” (Doc. 71). After reviewing a variety of evidence, including the report of a forensic accounting firm hired by the corporation, (see Doc. 71-1), the law firm recommended against advancement. In the law firm’s view, the Bylaws limited advancement to cases where the director or officer “acted in good faith and in a manner reasonably believed to be in or not opposed to the best

interests.” (Doc. 71-3 at 6). Based on the evidence it reviewed, the law firm found that Ron and Christine Carlson had misappropriated company funds for their personal benefit and the benefit of companies affiliated with them. “Such actions on their face were not in the ‘best interests’ of the Company, and under supporting case law, cannot be construed as ‘good faith’ for purposes of indemnification under Oklahoma law.” (Id. at 7). Accordingly, the firm concluded that “indemnification of expenses . . . in advance of final disposition is not proper due to the Federal Defendants’ failure to act in good faith and in a manner reasonably believed to be in or not opposed to the best interests of the Company.” (Id.). On December 2, 2020, about a week before the instant motion was filed, the plaintiff siblings executed a written consent exercising their purported authority as the majority

shareholders in the company. (Doc. 71-4). Citing their authority under the Bylaws, the accounting report, and the law firm’s findings, they resolved that CRC would not advance Ron and Christine Carlson’s litigation expenses because they had not acted in good faith and not in a matter reasonably believed to be in the best interest of the corporation. II. PRELIMINARY INJUNCTION STANDARD To obtain a preliminary injunction, the moving party must show: (1) he is substantially likely to succeed on the merits, (2) he will suffer irreparable injury if the injunction is denied, (3) his threatened injury outweighs the injury the opposing party will suffer under the injunction, and (4) the injunction would not be adverse to the public interest. State v. U.S. Env’t Prot. Agency, 989 F.3d 874, 883 (10th Cir. 2021). The grant or denial of a preliminary injunction is subject to the trial court’s discretion. Penn v. San Juan Hosp., Inc., 528 F.2d 1181, 1185 (10th Cir. 1975). Moreover, a preliminary injunction is never awarded as a matter of right, even when the moving party will suffer an inevitable harm. Bhd. of Locomotive Engineers v. Missouri-Kansas-Texas R.

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Commercial Resins Company Inc. v. Carlson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commercial-resins-company-inc-v-carlson-oknd-2021.