Doyle v. Hoyle

CourtDistrict Court, D. New Hampshire
DecidedJuly 20, 1995
DocketCV-92-244-SD
StatusPublished

This text of Doyle v. Hoyle (Doyle v. Hoyle) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doyle v. Hoyle, (D.N.H. 1995).

Opinion

Doyle v . Hoyle CV-92-244-SD 07/20/95 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Diana F. Doyle, individually

and as Trustee of DB Realty Trust

v. Civil N o . 92-244-SD

Wayne Hoyle; Hoyle Insurance, Inc. O R D E R

By order of this court dated March 1 4 , 1995, the parties to this action were given an additional 30 days to depose defendant Wayne Hoyle and file supplemental memoranda on the limited question of whether defendant Hoyle Insurance Agency's corporate form should be disregarded due to undercapitalization. The court has received the parties' supplemental memoranda and turns now to that question.

In arguing that Hoyle Insurance Agency's corporate veil should be pierced and that Wayne Hoyle should be held personally liable for breach of contract and warranty because of the undercapitalization of Hoyle Insurance Agency, plaintiff asserts that Massachusetts law should apply since the agency is a Massachusetts corporation. As defendants do not dispute this

contention, the court will apply Massachusetts law.1

"The principle of limited liability is a pillar of corporate

law." United Elec. Workers v . 163 Pleasant S t . Corp., 960 F.2d

1080, 1091 (1st Cir. 1992) (citing DeBreceni v . Graf Bros.

Leasing, Inc., 828 F.2d 8 7 7 , 879 (1st Cir. 1987), cert. denied, 484 U.S. 1064 (1988)). Limited liability allows individuals to take a calculated risk when they engage in the investment and entrepreneurial ventures central to a capitalist economy. If the venture fails, corporate shareholders lose only their interest in the corporation, not their homes or life savings. Of course, the principle of limited liability has itself been limited by the common law doctrine which permits the piercing of the corporate veil

DeBreceni, supra, 828 F.2d at 879.

Massachusetts courts "will pierce the corporate veil only

'in rare particular situations in order to prevent gross

inequity.'" Gurry v . Cumberland Farms, Inc., 550 N.E.2d 1 2 7 , 134

(Mass. 1990) (quoting My Bread Baking C o . v . Cumberland Farms,

Inc., 233 N.E.2d 7 4 8 , 752 (Mass. 1968)). See also Gordon Chem.

1 Although the court is applying Massachusetts law here, it notes that the law of New Hampshire is in accord with that of Massachusetts in this area. Accordingly, the outcome reached herein is the same one the court would have reached had New Hampshire law been applied.

2 C o . v . Aetna Cas. & Surety Co., 266 N.E.2d 653, 657 (Mass. 1971)

("'It is only where the corporation is a sham, or is used to

perpetrate deception to defeat a public policy, that it can be

disregarded.'") (quoting New England Theatres, Inc. v . Olympia

Theatres, Inc., 192 N . E . 9 3 , 97 (1934)). In deciding whether to

disregard the corporate form, Massachusetts courts weigh the

following factors: (1) common ownership; (2) pervasive control; (3) confused intermingling of business activity assets, or management; (4) thin capitalization; (5) nonobservance of corporate formalities; (6) absence of corporate records; (7) no payment of dividends; (8) insolvency at the time of the litigated transaction; (9) siphoning away of corporate assets by the dominant shareholders; (10) nonfunctioning of officers and directors; (11) use of the corporation for transactions of the dominant shareholders; (12) use of the corporation in promoting fraud.

Evans v . Multicon Constr. Corp., 574 N.E.2d 395, 398 (Mass. App.

Ct.) (citing Pepsi-Cola Metro. Bottling C o . v . Checkers, Inc., 754 F.2d 1 0 , 14-16 (1st Cir. 1985)), review denied, 577 N.E.2d

309 (Mass. 1991). The only factor at issue here is whether Hoyle

Insurance Agency has been inadequately capitalized.

"'Inadequate capitalization' means capitalization very small

in relation to the nature of the business of the corporation and

the risks the business necessarily entails." 1 WILLIAM M . FLETCHER,

3 FLETCHER CYCLOPEDIA OF THE LAW OF PRIVATE CORPORATIONS § 44.1, at 812

(perm. ed. rev. vol. 1990) (hereinafter FLETCHER'S CYCLOPEDIA).

[I]n regard to that amount of capital that constitutes sufficient capitalization, the following standard emphasizing economic viability rather than an inflexible computation of minimal capitalization should be used: A corporation is undercapitalized when there is an obvious inadequacy of capital, measured by the nature and magnitude of the corporate undertaking.

Id.

Hoyle Insurance Agency was incorporated in Massachusetts in

1973 for the purpose of "carry[ing] on the business exclusively of an insurance agent, broker or adjuster of fire losses."

Articles of Organization (Plaintiff's Exhibit C ) . The agency has

been operating continuously since that time and, according to its

accountant, "has never filed bankruptcy, or been declared

insolvent in any action in the Commonwealth of Massachusetts, or

filed an assignment for the benefit of creditors." Affidavit of

Paul Haggerty ¶ 5 (Defendants' Exhibit 1 ) . Further, Hoyle

Insurance "is able to meet its current debts in the ordinary

course of business as they become due." Id. ¶ 7 . Defendant's

accountant also opines that "Hoyle Insurance, Inc. is adequately

capitalized for the purpose of providing the services required of an insurance agency." Id. ¶ 8 .

4 Plaintiff contends that Hoyle Insurance is "grossly

undercapitalized" and is "an empty shell." Plaintiff's

Supplemental Memorandum at 4 , 6. In support thereof, plaintiff

submits the transcript from the deposition of defendant Wayne

Hoyle. Hoyle states that the agency's assets include personal

computers and related peripherals, office furniture and equipment, a car with a market value of $3,000, and a client

list. Deposition of Wayne Hoyle, Sr., at 59-61 (Plaintiff's

Exhibit A ) .

Plaintiff also submits the affidavit and expert's report of

Eric G. Gustafson,2 who opines "that the assets of the Hoyle

Agency are not reasonably adequate to meet its prospective

liabilities." Gustafson Affidavit ¶ 5 . Gustafson's opinion is

based on his review of Hoyle's deposition testimony, including

his testimony regarding the agency's assets and the fact that the

agency did not carry errors and omissions insurance, and his

review of an insurance binder filled out by Hoyle for plaintiff's

property. Id. ¶¶ 3-4. Gustafson states that "[s]ince the binder

fails to identify an insurance company, M r . Hoyle and his agency

2 Gustafson states in his affidavit that he "ha[s] been an insurance agent for 38 years and [is] the chairman of the Blake Insurance Agency, Inc. in Portsmouth, New Hampshire." Affidavit of Eric G. Gustafson ¶ 2 (Plaintiff's Exhibit B ) .

5 appear to be the entities issuing the binder and as such, are the

insurers of the property identified on the binder." Id. ¶ 4 .

As a preliminary matter, the court finds that the evidence

before i t , including the evidence regarding defendant's failure

to name an insurer on an insurance binder covering plaintiff's

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Related

GORDON CHEMICAL CO. INC. v. Aetna Casualty & Surety Co.
266 N.E.2d 653 (Massachusetts Supreme Judicial Court, 1971)
Evans v. Multicon Construction Corp.
574 N.E.2d 395 (Massachusetts Appeals Court, 1991)
Jindra v. City of Chicago
550 N.E.2d 1 (Appellate Court of Illinois, 1989)

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