Cuker v. Mikalauskas

35 Pa. D. & C.4th 87
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedFebruary 26, 1998
Docketno. 3470
StatusPublished

This text of 35 Pa. D. & C.4th 87 (Cuker v. Mikalauskas) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cuker v. Mikalauskas, 35 Pa. D. & C.4th 87 (Pa. Super. Ct. 1998).

Opinion

DiNUBILE, J.,

BACKGROUND

In 1995, Philadelphia Electric Company filed a motion for summary judgment seeking termination of the above-captioned minority shareholder derivative actions. When this motion was denied by the Court of Common Pleas of Philadelphia, PECO sought and ul[89]*89timately was granted extraordinary relief by the Supreme Court of Pennsylvania. Their decision is set forth in Cuker v. Mikalauskas, 547 Pa. 600, 692 A.2d 1042 (1997). The Supreme Court, applying the business judgment rule, remanded the case to this court for the purpose of holding a hearing to determine whether the actions of PECO’s board of directors through the appointment of a special litigation committee, acted properly in dismissing the derivative actions.

Pursuant to this directive, a hearing was held by this court. The Cuker Supreme Court opinion specifically directed the lower court to apply the following criteria and burden of proof in rendering a factual determination regarding the propriety of the PECO board’s action: (1) whether the SLC was disinterested and independent; (2) whether it was assisted by counsel who were disinterested and independent; (3) whether the SLC conducted an adequate investigation; and (4) whether the SLC rationally believed its decision was in the best interest of the corporation — did it act in good faith. The Supreme Court opinion also made reference to sections 7.02-7.10 and 7.13 of the ALI Principles (American Law Institute). The Cuker court placed the burden of proof on plaintiffs to show impropriety on the part of the board.

Applying the above-stated criteria to the facts presented at the hearing, this court concludes that plaintiffs failed to meet their burden of proof. Consequently, the above actions are terminated. The court will discuss each criteria as it relates to the facts found.

FINDINGS OF FACTS

(1) The Special Litigation Committee Was Independent and Disinterested

The facts established beyond any doubt that the three members of the SLC were impartial and unbiased and [90]*90that their decision was completely independent, disinterested and reasonable. All three members were experienced, sophisticated business executives with impeccable backgrounds. Prior to their appointment to the SLC, they had served as outside directors of PECO. That is, although they were directors, they were not officers or employees of the corporation.

Their appointment to the litigation committee occurred on June 28, 1993. The chairman, Nelson G. Harris, had a long and distinguished business career. He was an attorney, C.P.A., and former director and CEO of Tasty Baking Company. The other two members were James A. Hagen, past chairman of the Conrail board of directors, and Susan W. Catherwood. She is presently vice president of the Board of Trustees of the University of Pennsylvania, chairman of the University’s Health System, and a board member of the Pew Charitable Trusts and the Glenmede Corporation. None of the three had any financial, business, familial, or substantial social connections with the defendant board of directors of PECO.

As evidence that the SLC was not independent or disinterested, plaintiffs pointed to the fact that PECO’s board chairman and one of the defendants in this suit, Joseph F. Paquette Jr., had asked Mr. Hagen and Mrs. Catherwood to serve on the SLC. Further, it appeared that Mr. Paquette was the person who had asked Mr. Harris to join the PECO board as an outside director in 1989. These facts on their face, however, are not sufficient to carry plaintiffs’ burden of proof that Mr. Harris, Mr. Hagen, and Mrs. Catherwood did not act as independent and disinterested persons in deciding to terminate the derivative suit. And, plaintiffs could point to no additional facts to bolster this argument. Rather, PECO introduced evidence that Mr. Paquette did not tell Mr. Hagen or Mrs. Catherwood anything about the purpose of the SLC but only referred them [91]*91to PECO’s general counsel, James W. Durham, and that Mr. Paquette had no further contact with the SLC members during the decision-making process.

Plaintiffs also pointed to the fact that many of the PECO directors named as defendants in the shareholder derivative suits, as well as the non-defendant board members and the SLC members, served on business and charitable boards together. Although it is true that there may have been some interlocking directorships (the record is unclear what particular PECO board members served on what particular boards with the SLC members), there was no evidence that any relationships which might have developed as a result impinged upon the objectivity of the SLC members. For example, it appeared that numerous PECO board members were involved with the United Way charity, and that Mr. Harris and Mr. Hagen served on the board of the Philadelphia First Corporation with Mr. Paquette. It cannot be said that Messrs. Harris and Hagen were rendered incapable of disinterested or independent action as a result, however, as virtually all of the board members were associated either with United Way or with charities like the Philadelphia First Corporation. If SLC members were to be disqualified based on interlocking directorships, then it is likely no one would have been eligible to serve.

The court finds as fact that no member of the PECO board, whether named as defendants in the shareholder suits or not, attempted to influence the decision of the SLC in any way. There was no evidence that the defendant board members participated in the appointment of the SLC or took part in the SLC’s decision-making process regarding termination of the shareholder suits.

Plaintiffs argued that the members of the SLC were incapable of objective judgment since they were participating members of the PECO board and two of the [92]*92three served on the board’s audit committee at the time of the allegedly wrongful actions set forth in plaintiffs’ complaint; the allegations involved credit and collection issues. As further evidence of the impossibility of objectivity, plaintiffs pointed out that two of the three members of the SLC also served on the PECO board’s compensation committee which drew up Mr. Paquette’s compensation package. The SLC must have been biased in its assessment of Mr. Paquette’s performance, the plaintiffs conclude. As a matter of fact, the court took these factors into account in determining whether the members of the SLC were independent and disinterested, and concluded that these factors had no significant bearing on the decision reached by the SLC.

(2) The SLC’S Counsel Was Independent and Disinterested

The court also finds that counsel appointed to represent the SLC, the Philadelphia law firm of Dilworth, Paxson, Kalish & Kauffman was fair, impartial, disinterested and independent.

Following appointment of the SLC, general counsel for PECO, James W. Durham, submitted eight proposals from law firms wishing to represent the SLC.1 Mr. Durham’s sole responsibility was to determine whether any conflict of interest existed between these eight law firms and PECO. In its choice of counsel, the SLC was not restricted to these eight firms; after reviewing the proposals, however, the SLC was satisfied it could choose counsel from among the firms submitting proposals.

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Related

Cuker v. Mikalauskas
692 A.2d 1042 (Supreme Court of Pennsylvania, 1997)

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Bluebook (online)
35 Pa. D. & C.4th 87, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cuker-v-mikalauskas-pactcomplphilad-1998.