Gerlofs v. Citizens Bank, N.A.

CourtSuperior Court of Delaware
DecidedApril 29, 2024
DocketN23C-09-178 MAA CCLD
StatusPublished

This text of Gerlofs v. Citizens Bank, N.A. (Gerlofs v. Citizens Bank, N.A.) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gerlofs v. Citizens Bank, N.A., (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

GWEN I. GERLOFS, ) ) Petitioner/ ) C.A. No. N23C-09-178 MAA CCLD Counterclaim Respondent, ) ) v. ) ) CITIZENS BANK, N.A., ) ) Respondent/ ) Counterclaim Petitioner. ) ) ADAPTHEALTH LLC, ) ) Cross-Claim Respondent/ ) Counterclaim Petitioner. )

Submitted: March 7, 2024 Decided: April 29, 2024

Citizens Bank, N.A.’s Application for Fees and Costs: GRANTED, in part.

MEMORANDUM OPINION

Christopher P. Simon, Esquire (Argued) and Kevin S. Mann, Esquire, of CROSS & SIMON, LLC, Wilmington, Delaware, Attorneys for Gwen I. Gerlofs.

Ronald N. Brown, III, Esquire and Daniel P. Klusman, Esquire, (Argued), of DLA PIPER LLP, Wilmington, Delaware, Attorneys for Citizens Bank, N.A.

Steven L. Caponi, Esquire, Matthew B. Goeller, Esquire and Megan E. O’Connor, Esquire, (Argued), of K&L GATES LLP, Wilmington, Delaware, and Thomas R. DeCesar, Esquire, of K&L GATES LLP, Harrisburg, Pennsylvania, Attorneys for AdaptHealth, LLC.

Adams, J. INTRODUCTION

Plaintiff Gwen I. Gerlofs (“Gerlofs”) initiated this action to secure the release

of $4 million from an escrow account (the “Escrow Funds”) maintained by Citizens

Bank, N.A. (“Citizens”). AdaptHealth LLC (“AdaptHealth”), the buyer in a

September 2021 sale in which Gerlofs was the seller, had deposited the Escrow

Funds in connection with that sale. An agreement between Gerlofs, AdaptHealth,

and Citizens governs the Escrow Funds (the “Escrow Agreement”). When it came

time to release the Escrow Funds to Gerlofs, AdaptHealth made a last-minute

objection to stop the transfer. On November 3, 2023, the Court granted summary

judgment in favor of Gerlofs, holding that the plain language of the Escrow

Agreement supported disbursement of the Escrow Funds.

Though that holding resolved the primary dispute in this litigation, Citizens

now seeks indemnification of its costs pursuant to the Escrow Agreement.

AdaptHealth accepts that Citizens is contractually entitled to its full costs, but

Gerlofs disputes Citizens’ application. AdaptHealth and Gerlofs also disagree over

which of them is primarily responsible for Citizens’ costs. This is the Court’s

opinion on those issues.

For the reasons stated herein, Citizens’ application for fees and costs is

GRANTED as modified. Gerlofs and AdaptHealth shall each pay one-half of the

2 awarded fees and costs Citizens incurred before April 28, 2023. Gerlofs shall pay

all of the awarded fees and costs Citizens incurred on or after April 28, 2023.

FACTS AND PROCEDURAL HISTORY

I. The Escrow Agreement

Gerlofs, AdaptHealth, and Citizens entered the Escrow Agreement on

November 3, 2021.1 The Escrow Agreement was part of the transaction in which

Gerlofs sold Pumps It, Inc. (“Pumps It”) to AdaptHealth.2 The Escrow Agreement

called upon Citizens to be the “Escrow Agent,” with Gerlofs and AdaptHealth as the

“Escrow Parties.”3 Subject to its full terms, the core of the Escrow Agreement was

that AdaptHealth had one year to make claims against the Escrow Funds and then

Citizens would release any undisputed funds to Gerlofs within three business days

of November 2, 2022 (the “Termination Date”).

Citizens’ obligations as Escrow Agent were limited, and Citizens did not

agree to become a de facto arbitrator for Gerlofs and AdaptHealth. For example,

Section 6(a) of the Escrow Agreement provides:

Notwithstanding anything to the contrary in this Agreement, the Escrow Agent shall only disburse Escrow Funds from the Escrow Account pursuant to (i) joint written instructions from both of the

1 D.I. No. 1 (“Compl.”), Ex. A (“Escrow Agreement”). 2 Id. 3 Id. 3 Escrow Parties . . . or (ii) a final, non-appealable judgment, order or decree of a court of competent jurisdiction or arbitration award . . . .4

Section 8(e) of the Escrow Agreement adds:

In the event that the Escrow Agent shall be uncertain as to its duties or rights under this Agreement, or shall receive any certificate, statement, notice, instruction, direction or other instrument from any other party with respect to the Escrow Funds which, in the Escrow Agent’s reasonable and good faith opinion, is in conflict with any of the provisions of this Agreement, or shall be advised that a dispute has arisen with respect to the Escrow Funds or any part thereof, the Escrow Agent shall be entitled, without liability to any person, to refrain from taking any action other than to keep safely the Escrow Funds until the Escrow Agent shall be directed otherwise in accordance with Joint Instructions or an order of a court with jurisdiction over the Escrow Agent. The Escrow Agent shall be under no duty to institute or defend any legal proceeding, but may, in its discretion and at the expense of the Escrow Parties as provided in subjection (f) immediately below, institute or defend such proceedings.

Section 8(f), in turn, provides:

The Escrow Parties authorize the Escrow Agent, if the Escrow Agent is threatened with litigation or is sued, to interplead all interested parties in any court of competent jurisdiction and to deposit any particular Escrow Funds with the clerk of that court. In the event of any dispute under this Agreement, the Escrow Agent shall be entitled to petition a court of competent jurisdiction and shall perform any acts ordered by such court.

Along with those limits on Citizens’ obligations came limits on Citizens’

liability. The Escrow Agreement is laden with explicit limitations on the risk

4 Id. § 6(a) (emphasis added). 4 Citizens agreed to bear in its role as Escrow Agent.5 Most pertinent to this dispute,

Section 9 of the Escrow Agreement provides:

The Escrow Parties agree jointly and severally to indemnify the Escrow Agent for, and to hold it harmless against, any and all claims, suits, actions, proceedings, judgments, deficiencies, damages, settlements, liabilities and expenses (including reasonable legal fees and expenses of attorneys chosen by the Escrow Agent) as and when incurred, arising out of or based upon any act, omission, alleged act or alleged omission by the Escrow Agent or any other cause, in any case in connection with the acceptance of, or performance or non-performance by the Escrow Agent of, any of the Escrow Agent's duties under this Agreement, except as a result of the Escrow Agent's bad faith, willful misconduct or gross negligence. As between the Escrow Parties, each of them shall bear the foregoing in proportion to their respective responsibility, if any, with respect to the foregoing, or, if neither of them bears greater responsibility than the other, each Escrow Party shall bear one-half of the foregoing.6

The Escrow Agreement also contained a collection of provisions to resolve

any claims made by AdaptHealth. For purposes of this fee application, the critical

point is that AdaptHealth was required to make claims against the Escrow Funds, if

at all, “on or before November 2, 2022 (the ‘Termination Date’).”7 The Escrow

Agreement stated, “[t]he Escrow Agent shall disregard any Claims that are not

submitted by notice given on or before the Termination Date.”8

5 See, e.g., id. §§ 3, 6(a), 7, 8(a)–(e), 9, 16, 19(g). 6 Id. § 9. 7 Id. § 6(b). 8 Id. 5 II. The Escrow Dispute

On November 3, 2022, Citizens emailed AdaptHealth and Gerlofs, advising

them that the Termination Date had passed and “Citizens Bank has not received, nor

is aware of, any outstanding or pending claims.”9 In that email, Citizens asked the

parties to “please let [Citizens] know” if there were any unresolved claims. 10 That

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Gerlofs v. Citizens Bank, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gerlofs-v-citizens-bank-na-delsuperct-2024.