Daniel Felt and Susan Kern v. David Felt and Felt Farms LLC

CourtCourt of Appeals of Iowa
DecidedJune 5, 2019
Docket18-0710
StatusPublished

This text of Daniel Felt and Susan Kern v. David Felt and Felt Farms LLC (Daniel Felt and Susan Kern v. David Felt and Felt Farms LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniel Felt and Susan Kern v. David Felt and Felt Farms LLC, (iowactapp 2019).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 18-0710 Filed June 5, 2019

DANIEL FELT and SUSAN KERN, Plaintiffs-Appellants,

vs.

DAVID FELT and FELT FARMS LLC, Defendants-Appellees. ________________________________________________________________

Appeal from the Iowa District Court for Dallas County, Bradley McCall,

Judge.

Plaintiffs challenge whether Felt Farms LLC had any members within ninety

days after Richard Felt’s death. REVERSED AND REMANDED.

Richard McConville and Michael J. Carroll of Coppola, McConville, Carroll,

Hockenberg & Flynn, P.C., West Des Moines, for appellants.

Lylea Dodson Critelli and Nicholas Critelli of Critelli Law, P.C., Des Moines,

for appellees.

Heard by Vogel, C.J., and Mullins and Bower, JJ. 2

BOWER, Judge.

Daniel Felt and Susan Kern (née Felt) appeal the district court ruling, finding

a limited liability company (LLC) formed by their father, Richard Felt, did not

dissolve following his death. We find the contractual requirements for membership

were not met within ninety days of Richard’s death, and the LLC dissolved as a

matter of law.

I. Background Facts & Proceedings

Richard Felt was a third-generation Dallas County farmer. Richard farmed

with his brother and their father after returning from the Korean War in the 1950s

until their father’s retirement, then the brothers continued farming with each other.

When Richard’s brother retired in the late 1980s, they divided their real estate and

farming property. Richard’s property included approximately one hundred acres

west of Waukee that held the house he grew up in and where he and his wife

Patricia lived. In 1988, Richard and Patricia executed wills leaving all their property

to each other, and then equally to their children upon death of the second spouse.

Richard and Patricia were the parents of three children: Susan, David, and

Daniel. In 1990, David joined Richard in a joint farming operation. Richard and

Patricia purchased an additional 156-acre farm between Waukee and Adel, which

included a house for David’s family to live in.1 As part of their oral farming operation

agreement, David purchased any new equipment needed and paid for repairs for

the farms and the homes. Approximately ten years after David joined the farming

operation, Daniel asked to join the family business; David told Daniel the farms

1 David and his wife purchased the house and a surrounding five-acre plot from Richard and Patricia in 2012. 3

could not support another family at that time. Richard and David continued to farm

together, and Daniel did not ask again to join.

In the mid-2000s, when Richard mostly retired from farming, Richard and

David entered into an oral lease where David paid cash rent and paid a number of

Richard and Patricia’s bills. Patricia died in 2013. Soon after, Richard was

diagnosed with cancer and underwent treatment from late 2013 until shortly before

his death on November 4, 2015.

In early 2015, Richard began discussing the creation of a limited liability

company (LLC) with his attorney, Sam Braland. Richard was interested in potential

tax benefits and wanted to keep the farms in the family. Braland had not previously

formed a LLC, so he studied the Iowa LLC statutes and obtained a template of a

farm LLC from the Iowa State Bar Association. He did not consult with an attorney

with more LLC experience. Braland drew up a certificate of organization and an

operating agreement. On August 28, Richard signed the organizational

documents and operating agreement for a manager-managed LLC named Felt

Farms LLC. Richard transferred all his real property to the LLC in exchange for

ownership of 100 Class A Units (income units) and 900 Class B Units (ownership

and voting units).2 Richard and David were appointed and signed the agreement

as managers of the LLC, and Richard signed separately as its only member.3

Richard did not change his will, which continued to leave his property in equal

2 At the same time, Richard also transferred two buildings on the farms to David. The buildings were transferred to David for no consideration due to his extensive remodeling of the buildings at his own cost to create a storage business. 3 David testified to knowing he was not a member of the LLC when he signed the operating agreement as manager. 4

shares to his children. Richard did not tell Daniel or Susan anything about the

LLC.

Braland also prepared power-of-attorney documents granting David the

authority to make decisions on behalf of Richard. In the months prior to Richard’s

death, David took action as financial power-of-attorney to change several of

Richard’s investments to payable-on-death accounts evenly split among himself

and his siblings. He also transferred some deposits to the LLC to fund its

operation. Richard died on November 4. After Richard’s death, David used

Richard’s remaining funds to pay funeral and other outstanding expenses, then

split the remainder evenly among himself and his siblings. Richard’s will was not

admitted to probate until September 2017.

Following Richard’s death, David informed Daniel and Susan the family

properties were in an LLC. In December 2015, Braland wrote to the siblings to

provide them documents relating to Richard’s estate. The letter informed the

siblings,

With regard to the limited liability company, the three of you have succeeded in equal shares to all ownership units of the company. I believe it would be prudent for all of us to meet in January for the purpose of issuing certificates of ownership to each of you, and to briefly discuss the operation of the company, and to answer questions you might have.

The parties did not meet with Braland in January. Effective January 14,

2016, David obtained liability insurance for Felt Farms LLC, which he verified

covered him and his siblings as members on May 4, 2016. The named insured

parties for the farms’ property insurance was changed to Felt Farms LLC and

David superseded Richard effective November 5, 2015. Susan and Daniel 5

consulted with their own attorney regarding the LLC and its implications during this

period.

In September 2016, Braland consulted with another attorney with more

experience in LLCs. After learning of the distinction between transferees and

members, David issued equal interests to himself, Susan, and Daniel. On October

18, Daniel and Susan proposed a member-managed LLC or partition of the land.

David did not agree to the proposed changes.

In December 2016, David wrote checks to himself and his siblings from the

Felt Farms LLC checking account. David termed the payments as 2016

distributions which consisted of cash rent David had paid the LLC and money in

the account prior to Richard’s death. All three siblings cashed their checks.4 The

LLC provided K-1s to each of the siblings for tax purposes.5 In March 2017, David

unilaterally under his authority as manager arranged for a letter of credit for the

LLC, and signed the documents under his authority as manager of the LLC.

On February 21, 2017, Daniel and Susan filed suit challenging the creation

of the LLC and some of Richard’s inter vivos transfers under several theories—

including three types of tortious interference and elder abuse—and requesting

declaratory judgment on the status of the LLC. They alleged David exercised

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Daniel Felt and Susan Kern v. David Felt and Felt Farms LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniel-felt-and-susan-kern-v-david-felt-and-felt-farms-llc-iowactapp-2019.