Emanuel v. SBA

CourtDistrict Court, D. New Hampshire
DecidedOctober 16, 1998
DocketCV-97-012-JD
StatusPublished

This text of Emanuel v. SBA (Emanuel v. SBA) 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
Emanuel v. SBA, (D.N.H. 1998).

Opinion

Emanuel v. SBA CV-97-012-JD 10/16/98 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Michael S. Emanuel, et al.

v. Civil No. 97-012-JD

United States Small Business Administration

O R D E R

Michael Emanuel, the pro se plaintiff, has asserted various

claims against the defendant, the United States Small Business

Administration (the "SBA"), arising from the SBA's foreclosure

sale of the business property of Quality Discount Foods Corp.

("Quality"), a company owned by Emanuel. Before the court is the

defendant's motion to dismiss the plaintiff's amended complaint

(document no. 27).

Background

The court incorporates by reference the factual background

discussed in its order of March 6, 1998. See Emanuel v. United

States Small Bus. Admin., No. 97-012-JD, slip op. at 1-2 (D.N.H.

Mar. 6, 1998). In that order the court rejected counts one and

three of the plaintiff's initial complaint, alleging in essence

misrepresentation or fraud, because it lacked subject matter

jurisdiction over those claims. See id. at 5-8. In count two. however, the plaintiff asserted that the defendant breached

contractual duties owed him. The defendant moved for dismissal

of this claim as well, asserting, inter alia, that the claim was

barred by the statute of limitations. However, the plaintiff

failed to plead this claim with sufficient particularity to allow

the court to resolve the issue. The court therefore granted

leave to the plaintiff to amend his complaint as follows:

the plaintiff's complaint must include clear, specific statements identifying: (1) the contract and terms that the defendant has allegedly breached; (2) the duties the defendant allegedly owed the plaintiff that arose from the contract; and (3) the actions of the defendant that allegedly breached the contractual duties owed the plaintiff.

Id. at 10.

On April 3, 1998, the plaintiff filed his amended complaint.

In the amended complaint, the plaintiff alleges that: (1)

Quality borrowed $261,600 from the SBA as a "displaced business

loan" in 1974 to purchase a site for a supermarket (the "Quality

property")1; (2) Quality encountered financial difficulties and

purchased inventory with money allocated for the payment of real

estate taxes; (3) the SBA foreclosed on the Quality loan; (4) the

principle on the loan had been reduced to roughly $90,000; (5)

the Quality property was sold by the SBA at public auction for

1The record indicates that the plaintiff co-signed the loans as a guarantor.

2 $134,OOO2; (5) there were no other bidders at the auction besides

the purchasers; (6) the Quality property was subsequently resold

by the purchasers for $350,000; (7) the city of Laconia appraised

the Quality property at $959,000; (8) the property was appraised

by another creditor at $500,000 to $700,000; (9) the SBA

appraised the property at $300,000; (10) the SBA's appraisal was

inaccurate as it used improper comparables; and (11) the public

auction was conducted inappropriately as it was held on the

coldest day of the year.

The plaintiff asserts that the SBA is liable because it

should not have initiated the foreclosure on the property, the

property should not have been sold at auction for less than its

value, and the conduct of the sale was inappropriate as the sale

was held on the coldest day of the year. The plaintiff also

asserts a novel claim of a conflict of interest between the SBA,

United States Senator Judd Gregg, and the New Hampshire law firm

of Sullivan and Gregg. The defendant has again moved for

dismissal, re-asserting its earlier arguments as well as new

arguments in response to the amended complaint.

2The defendants assert that the sale price included payment of $43,000.00 for overdue taxes in addition to the $134,000.00.

3 Discussion

A motion to dismiss under Federal Rule of Civil Procedure

12(b)(6) is one of limited inquiry, focusing not on "whether a

plaintiff will ultimately prevail but whether the claimant is

entitled to offer evidence to support the claims." Scheuer v.

Rhodes, 416 U.S. 232, 236 (1974). Accordingly, the court must

take the factual averments contained in the complaint as true,

"indulging every reasonable inference helpful to the plaintiff's

cause." Garita Hotel Ltd. Partnership v. Ponce Fed. Bank, 958

F.2d 15, 17 (1st Cir. 1992); see also Dartmouth Review v.

Dartmouth College, 889 F.2d 13, 16 (1st Cir. 1989). In the end,

the court may grant a motion to dismiss under Rule 12(b) (6)

"'only if it clearly appears, according to the facts alleged,

that the plaintiff cannot recover on any viable theory.'"

Garita, 958 F.2d at 17 (quoting Correa-Martinez v. Arrillaaa-

Belendez, 903 F.2d 49, 52 (1st Cir. 1990)).

"Our judicial system zealously guards the attempts of pro se

litigants" to represent their own interests. See Ahmed v.

Rosenblatt, 118 F.3d 886, 890 (1st Cir. 1997), cert, denied, 118

S.Ct. 1165 (1998). The court has a duty to liberally construe a

pro se plaintiff's complaint. See id. If a pro se plaintiff

alleges sufficient facts from which the court can intuit a cause

of action, even if the plaintiff imperfectly pleads the cause of

4 action, the court must not dismiss the case. See id. "However,

pro se status does not insulate a party from complying with

procedural and substantive law." Id.

A. Commercial Reasonableness

The plaintiff has asserted that the SBA undervalued the

property at issue, wrongfully sold the property for an

insufficient amount, and should not have conducted the sale,

inter alia, on the coldest day of the year. The issue presented

by the plaintiff's allegations is whether there was a duty on

behalf of the SBA to realize some minimum price and to engage in

some minimum standard of conduct in connection with its

foreclosure of the property at issue.

This case arises from a nationwide federal program designed

to assist small businesses in part through dispersing federal

funds in the form of loans or guarantees under the auspices of

the SBA. Federal legislation does not address the rights and

obligations of the SBA as a mortgagee in foreclosing upon

property. Many circuits have found incorporation of state law

warranted to fill the interstices of the federal legislation.

In United States v. Conrad Publishing Co., the Eighth

Circuit incorporated the Uniform Commercial Code ("UCC"), as

adopted by North Dakota, into federal law and upheld the district

5 court's determination that the SBA had not conducted a

foreclosure in a commercially reasonable manner. See 589 F.2d

949, 952-54 (8th Cir. 1978) . In Great Southwest Life Ins. Co. v

Frazier, the Ninth Circuit incorporated the UCC, as adopted by

Idaho, into federal law, and found that: (1) a co-maker of a

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Ahmed v. Rosenblatt
118 F.3d 886 (First Circuit, 1997)
United States v. Bernard v. Baus
834 F.2d 1114 (First Circuit, 1987)
Jorge Correa-Martinez v. Rene Arrillaga-Belendez
903 F.2d 49 (First Circuit, 1990)
Pridgen v. Andresen
113 F.3d 391 (Second Circuit, 1997)
Tuepker v. Farmers Home Administration
525 F. Supp. 237 (W.D. Missouri, 1981)
Copake Lake Development Corp. v. United States Government
490 F. Supp. 386 (E.D. New York, 1980)
Murphy v. Financial Development Corp.
495 A.2d 1245 (Supreme Court of New Hampshire, 1985)
First NH Mortgage Corp. v. Greene
653 A.2d 1076 (Supreme Court of New Hampshire, 1995)

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