EDWARD CRAWFORD v. DUNCAN SCOTT

CourtCourt of Appeals of Georgia
DecidedJune 20, 2023
DocketA23A0480
StatusPublished

This text of EDWARD CRAWFORD v. DUNCAN SCOTT (EDWARD CRAWFORD v. DUNCAN SCOTT) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EDWARD CRAWFORD v. DUNCAN SCOTT, (Ga. Ct. App. 2023).

Opinion

FOURTH DIVISION RICKMAN, C. J., DILLARD, P. J., and PIPKIN, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 20, 2023

In the Court of Appeals of Georgia A23A0480. CRAWFORD v. SCOTT et al.

PIPKIN, Judge.

Edward Crawford sued his former business partners, Appellees Duncan and

Graham Scott, for multiple causes of action following Crawford’s termination of

employment from Floorcare Specialists, Inc., (“Floorcare”) and subsequent removal

from the company’s Board of Directors.1 The trial court granted partial summary

judgment on Crawford’s claims of wrongful termination and breach of fiduciary duty,

and he appeals. For the reasons discussed below, we affirm the partial grant of

summary judgment as to Crawford’s claims of wrongful termination and breach of

fiduciary duty based upon Crawford’s wrongful termination. However, we reverse the

1 Crawford also included Floorcare as a party defendant in the cause of action. grant of summary judgment as to the remainder of Crawford’s breach of fiduciary

duty claim.

“Summary judgment is appropriate ‘if the pleadings, depositions, answers to

interrogatories, and admissions on file, together with the affidavits, if any, show that

there is no genuine issue as to any material fact and that the moving party is entitled

to a judgment as a matter of law.’” Yim v. Carr, 349 Ga. App. 892, 893 (1) (827 SE2d

685) (2019) (quoting OCGA § 9-11-56 (c)). On appeal, “we owe no deference to the

trial court’s ruling and we review de novo both the evidence and the trial court’s legal

conclusions. Moreover, we construe the evidence and all inferences and conclusions

arising therefrom most favorably toward the party opposing the motion.” (Citations

and punctuation omitted.) Bryant v. Optima Intl., 339 Ga. App. 696, 696 (792 SE2d

489) (2016).

So viewed, the evidence shows that, in January 2019, Crawford was the Chief

Financial Officer and Chief Operating Officer of Floorcare. He also served on the

Board of Directors with Duncan and Graham and was a minority shareholder in the

company. It is undisputed that, at all relevant times, Crawford did not have a written

employment contract with Floorcare. On January 2, 2019, Crawford arrived at the

office in what appeared to be an intoxicated state. According to Duncan, Crawford

2 was loud, vulgar, and belligerent, and eventually left the premises. Crawford later

contested the allegation that he was intoxicated by providing Duncan with medical

records indicating that Crawford might have suffered a hyperglycemic episode, the

symptoms of which are consistent with appearing intoxicated. After speaking with

other employees about Crawford’s behavior, Duncan delivered a termination letter

to Crawford on January 18, 2019, ending Crawford’s employment with the company.

Crawford was subsequently removed from the Board of Directors, but maintained his

status as a minority shareholder.

Thereafter, Crawford filed the instant action alleging, among other things,2 that

he was wrongfully terminated and that Appellees breached certain fiduciary duties

owed to him, such as “wrongfully terminating Mr. Crawford, failing and refusing to

reimburse Mr. Crawford for . . . [e]xpenses, destroying Mr. Crawford’s [p]ersonal

[p]roperty, and failing to manage and act in the interest of Floorcare.”3 Following

discovery, Appellees moved for partial summary judgment on these claims to the

extent that they were predicated on Crawford’s termination. In their motion,

2 Crawford also asserted claims for breach of bylaws, judicial dissolution, conversion, and money had and received. Those claims remain pending below. 3 In their answer to the complaint, Appellees asserted numerous affirmative defenses, including “lack of contract.”

3 Appellees argued that Crawford was an at-will employee who could be terminated

without cause, that his status as an at-will employee provided no action for breach of

fiduciary duty, and that the business judgment rule prevented relief for a claim of

breach of fiduciary duty based upon Crawford’s termination from the company. In

response, Crawford asserted that there was a genuine issue of material fact as to

whether he was an at-will or a contractual employee. Specifically, Crawford argued

that he had an implied, verbal, one-year employment contract with Floorcare that, he

alleged, placed him within the exceptions of OGCA § 34-7-1.4 In support of this

argument, Crawford relied upon the following portions of his own affidavit:

11. Floorcare’s officers, including its President/CEO and its Chief Operations Officer received an annual salary set by the Board of Directors. 12. Floorcare’s Board of Directors historically and as a matter of routine practice made annual reviews of its officers at an annual meeting. Its Board of Directors made evaluations concerning the officers and their compensation on an annual basis. 13. Annually at a meeting the Board of Directors approved the renewal of the officer’s employment and set the officer’s salary during that annual term.

4 Under OCGA § 34-7-1,”[i]f a contract of employment provides that wages are payable at a stipulated period, the presumption shall arise that the hiring is for such period, provided that, if anything else in the contract indicates that the hiring was for a longer term, the mere reservation of wages for a lesser time will not control. An indefinite hiring may be terminated at will by either party.”

4 14. In 2017, the Board of Directors reduced the officers’ salaries by 33% – from $150,000 to $100,000. The Board of Directors committed to reconsider the officer’s positions and annual salary with Floorcare in one year, as was Floorcare’s practice. 15. In 2018, the Board of Directors renewed the officer[s’] employment at Floorcare for a term of one year at the same salary as provided in 2017.

Crawford also relied on minutes from some of the Board of Directors’ meetings that

had occurred in 2017 and 2018, and on portions of the employee handbook, to argue

that a jury question existed as to whether he had an implied, verbal employment

contract. As to his claim of breach of a fiduciary duty, Crawford argued that

Appellees “acted in bad faith with the intent of depriving Crawford of his interests

in Floorcare” and that, since Crawford’s removal, Duncan Scott has

“misappropriate[d] Floorcare assets and usurp[ed] corporate opportunities of

Floorcare” for the benefit of another company.

After a hearing, the trial court granted Appellees’ partial motion for summary

judgment for wrongful termination and for breach of a fiduciary duty based upon

wrongful termination, finding that Crawford was an at-will employee subject to

termination without cause. The trial court also construed the remaining portion of

Crawford’s claim for a breach of fiduciary duty as “a veiled derivative action” and,

sua sponte, granted partial summary judgment on the entire claim.

5 1. On appeal, Crawford maintains that there is a genuine issue of material fact

concerning whether he had a verbal, implied, one-year employment contract that was

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EDWARD CRAWFORD v. DUNCAN SCOTT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-crawford-v-duncan-scott-gactapp-2023.