Envtl. Power Corp. v. Livingston

CourtSuperior Court of Maine
DecidedJuly 28, 2010
DocketYORcv-10-102
StatusUnpublished

This text of Envtl. Power Corp. v. Livingston (Envtl. Power Corp. v. Livingston) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Envtl. Power Corp. v. Livingston, (Me. Super. Ct. 2010).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION YORK, ss. DOCKET NO. CV-10-102 , ' " ,.. .~ L ~

ENVIRONMENTAL POWER CORPORATION,

Plaintiff

v. ORDER

DONALD A. LIVINGSTON,

Defendant

This action arises from three secured, payable-on-demand promissory notes

defendant Donald Livingston gave to plaintiff Environmental Power Corporation

("EPC"). EPC filed its complaint to foreclose its security interest and collect payment on

the notes. The plaintiff's motions to dismiss defendant Livingston's counterclaims and

attach $384,198.31 are before the court.

BACKGROUND Plaintiff EPC is a Delaware corporation headquartered in Tarrytown, New York.

(Pl.' s Compl. en 1.) Mr. Livingston is a former executive officer of EPC and currently

resides in York, Maine. (Pl.'s CompI. en 2; Def.'s Countercl. en 1.) Mr. Livingston executed

three promissory notes in favor of EPC between 1993 and 2001, reflecting an aggregate

principal amount of $528,280.50. (Pl.'s CompI. enen 4-6.) All three notes are payable on

demand, and all contain choice of law provisions. (Pl.' s CompI. en 7; Def.'s Counterc1.

enen 28, 31.) The first note states that it will be governed by the laws of Massachusetts, while the second and third notes invoke the laws of New Hampshire. (Def.'s Countercl.

errerr 28, 31.)

The notes are currently secured by 165,000 shares of EPC stock held by EPC in

Mr. Livingston's name. (PI.'s CompI. err 11.) The notes reference a larger number, but the

shares have been reduced through reverse stock splits. (PI.'s CompI. err 11 n.1.) EPC

claims that Mr. Livingston owed $410,498.31 as of September 20, 2009, with interest

accruing thereafter. (PI.'s CompI. err 8.) EPC mailed Mr. Livingston a demand letter on

October 15, 2009, but the defendant has not tendered payment. (PI.'s CompI. errerr 9-10.)

Mr. Livingston contends that the loans evinced by the promissory notes were in

fact a sham. He explains that he and other executives at EPC received employee

incentive options allowing them to acquire shares of EPC on favorable terms as part of

their total compensation. (Def.'s Countercl. err 2.) As EPC's publicly traded shares rose to

certain levels, Mr. Livingston and other executives sought to exercise these options.

(Def.'s Countercl. err 3.) This created a problem for EPC, however, because it would force

EPC to issue additional capital stock and dilute its market value. (Def.'s Countercl. err 4.)

To avoid this scenario, Mr. Livingston claims that EPC, through its board of

directors, proposed a transaction whereby the company would lend the executives the

funds necessary to exercise their options, and in exchange EPC would take a security

interest in the shares and retain their physical possession. (Def.'s Countercl. err 5.) Mr.

Livingston contends that the resulting transaction was revenue neutral when

conducted, with any gam or loss deferred until the loans were satisfied. (Def.'s

Countercl. err 7.) He also contends that the parties understood that the liquidation of the

secured shares would satisfy the notes. (DeL's Countercl. err 8.)

Mr. Livingston separated from EPC in approximately January 2007. (Def.'s

Countercl. err 1.) He allegedly owned 435,000 unencumbered shares of EPC in addition

2 to the 165,000 shares securing the notes. (Def.'s Countercl. <]I 9.) That year, EPC shares

reached a high value of approximately $9.50 per share. (Def.'s Countercl. <]I 10.) After

leaving the company, Mr. Livingston approached EPC's board of directors to discuss a

block transfer of his unencumbered shares. (Def.'s Countercl. <]I 11.) The board refused

to authorize the transfer on the ground that Mr. Livingston was a corporate insider.

(Def.'s Countercl. <]I 11.) EPC's share value began to tumble shortly thereafter. (Def.'s

Countercl. <]I 12.) As of April 1, 2010, the stock was trading at approximately $0.22 per

share. (Pl.'s CompI. <]I 17.)

EPC filed a verified complaint and motion to attach on April 8, 2010. The

complaint was sworn to and subscribed by EPC's senior vice president and chief

financial officer so that it could also serve as an affidavit supporting the motion to

attach. The complaint lists four claims. Count I seeks to enforce the notes by their terms,

Count II seeks to foreclose the security interest pursuant to 11 M.R.S. § 9-1601, Count III

alleges unjust enrichment, and Count IV asserts a claim for money lent. Mr. Livingston

has filed a counterclaim, also with four counts. Count I alleges tortious interference

with an economic advantage, Count II asserts breach of fiduciary duty, and Counts III

and IV allege violations of Massachusetts's and New Hampshire's consumer protection

laws. On June 8, 2010, EPC filed this motion to dismiss all of the defendant's

counterclaims.

DISCUSSION

1. Plaintiff's Motion to Dismiss Counterclaims

II A motion to dismiss tests the legal sufficiency of the complaint." Heber v.

Lucerne-ill-Maille Village Corp., 2000 ME 137, <]I 7, 755 A.2d 1064, 1066 (quoting McAfee v.

Cole, 637 A.2d 463, 465 (Me. 1994)). The Court examines lithe complaint in the light most

favorable to the plaintiff to determine whether it sets forth elements of a cause of action

3 or alleges facts that would entitle the plaintiff to relief pursuant to some legal theory."

Id. (quoting McAfee, 637 A.2d at 465). "For purposes of a 12(b)(6) motion, the material

allegations of the complaint must be taken as admitted." McAfee, 637 A.2d at 465.

"Dismissal is warranted when it appears beyond a doubt that the plaintiff is entitled to

no relief under any set of facts that [s]he might prove in support of [her] claim."

Johanson v. Dunnington, 2001 ME 169, <[ 5, 785 A.2d 1244, 1245-46.

Mr. Livingston's Count I alleges that EPC tortiously interfered with an economic

advantage. To prove tortious interference, Mr. Livingston must prove: "(1) that a valid

contract or prospective economic advantage existed; (2) that [EPC} interfered with that

contract or advantage through fraud or intimidation; and (3) that such interference

proximately caused damages." Currie v. Indus. Sec., Inc., 2007 ME 12, <[ 31, 915 A.2d 400,

408. (quoting Rutland v. Mullen, 2002 ME 98, <[ 13, 798 A.2d 1104, 1110) (quotations

omitted). The gist of his claim is that EPC wrongfully prevented him from selling his

shares in 2007.

While Mr. Livingston has not alleged the existence of any contract, his

investment interest in his shares probably does constitute a prospective economic

advantage. See Rutland, 2002 ME 98, <[<[ 4, 12-13, 798 A.2d at 1108, 1110 (inveshnent

interest in developable land was a prospective economic advantage). However, Mr.

Livingston has not adequately pleaded any facts supporting the elements of fraud. See

id. <[ 14, 798 A.2d at 1111 (elements of fraudulent interference identical to elements of

fraud at common law). His claim must therefore be based on intimidation.

"Interference by intimidation involves unlawful coercion or extortion." Id. <[ 16,

798 A.2d at 1111 (citing Black's Law Dictionary 827 (7th ed. 1999)). Intimidation "exists

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Related

Heber v. Lucerne-In-Maine Village Corp.
2000 ME 137 (Supreme Judicial Court of Maine, 2000)
McAfee v. Cole
637 A.2d 463 (Supreme Judicial Court of Maine, 1994)
Chase v. Dorais
448 A.2d 390 (Supreme Court of New Hampshire, 1982)
Morris v. Resolution Trust Corp.
622 A.2d 708 (Supreme Judicial Court of Maine, 1993)
Manning v. Zuckerman
444 N.E.2d 1262 (Massachusetts Supreme Judicial Court, 1983)
Rutland v. Mullen
2002 ME 98 (Supreme Judicial Court of Maine, 2002)
Pombriant v. Blue Cross/Blue Shield of Maine
562 A.2d 656 (Supreme Judicial Court of Maine, 1989)
Currie v. Industrial Security, Inc.
2007 ME 12 (Supreme Judicial Court of Maine, 2007)
Bryan R. v. Watchtower Bible & Tract Society of New York, Inc.
1999 ME 144 (Supreme Judicial Court of Maine, 1999)
Johanson v. Dunnington
2001 ME 169 (Supreme Judicial Court of Maine, 2001)

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Envtl. Power Corp. v. Livingston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/envtl-power-corp-v-livingston-mesuperct-2010.