In Re Allegiant Travel Co. Stockholder Derivative Litigation

CourtDistrict Court, D. Nevada
DecidedDecember 18, 2020
Docket2:18-cv-01864
StatusUnknown

This text of In Re Allegiant Travel Co. Stockholder Derivative Litigation (In Re Allegiant Travel Co. Stockholder Derivative Litigation) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Allegiant Travel Co. Stockholder Derivative Litigation, (D. Nev. 2020).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 IN RE ALLEGIANT TRAVEL CO. Case No.: 2:18-cv-01864-APG-DJA STOCKHOLDER DERIVATIVE 4 LITIGATION1 Order Granting Motion to Dismiss

5 [ECF No. 21]

7 This is a shareholder derivative action against several directors and officers of Allegiant 8 Travel Company (Allegiant). Plaintiffs Mark Fullenkamp and Charles Blackburn, on behalf of 9 nominal defendant Allegiant, sue several current and former officers and directors of Allegiant 10 for breach of fiduciary duty, unjust enrichment, breach of fiduciary duty through insider trading, 11 and violations of Section 14 of the Securities Exchange Act of 1934. The defendants are 12 Maurice J. Gallagher, Jr., John Redmond, Gregory Anderson, Scott Sheldon, Eric Gust, Charles 13 W. Pollard, Linda A. Marvin, Gary F. Ellmer, and Montie R. Brewer. 14 The defendants move to dismiss the plaintiffs’ claims, arguing that demand is not 15 excused and even if it were, the allegations in the second amended complaint (SAC) are 16 inadequate. The plaintiffs respond that demand would have been futile primarily because the 17 director defendants face a substantial likelihood of liability and have business relationships with 18 Gallagher. Because the plaintiffs did not establish demand futility, I grant the defendants’ 19 motion to dismiss. 20 / / / / 21 / / / / 22

23 1 Because this case was consolidated, the clerk is directed to amend the caption to include this updated case name. 1 I. BACKGROUND 2 Allegiant is a travel company that operates a commercial airline. According to the SAC, 3 Allegiant has “skimp[ed] on safety and maintenance, from at least mid-2014 to the present.” ECF 4 No. 20 at 2. The plaintiffs allege that Gallagher used a strategy of forgoing safety expenses, and

5 that strategy “became a public problem for Allegiant in 2015,” when its fleet made 77 6 “unexpected landings for serious mechanical failures” and five of its planes “failed midair within 7 the span of four hours.” Id. The plaintiffs further allege that all defendants breached their 8 fiduciary duties to the company because they knew “Allegiant was engaging in a scheme to keep 9 safety and maintenance costs low” but “continued to allow the scheme to occur.” Id. at 46. 10 The SAC alleges that these safety problems caught the attention of media organizations, a 11 large shareholder, and a union. The SAC states that in 2015, the New York Times reported on 12 Allegiant’s safety problems, and the Teamsters Aviation Mechanics Coalition reported a 13 “dangerous paradigm” related to maintenance procedures. Id. at 25. In January 2016, a letter 14 from a large Allegiant shareholder, CtW Investment Group, allegedly discussed safety issues and

15 called for measures such as a safety committee. Id. at 20-21. And in November 2016, the Tampa 16 Bay Times reported on an accidentally unredacted report from the Federal Aviation 17 Administration finding “deliberate and systemic acts of noncompliance” regarding Allegiant’s 18 maintenance. Id. at 18, 27. 19 CBS News devoted part of its 60 Minutes show to safety concerns about Allegiant in 20 April 2018. Id. at 3. The SAC alleges that three defendants sold Allegiant shares worth $2.3 21 million “just over a month prior” to the 60 Minutes segment. Id. The plaintiffs allege that these 22 defendants were “certainly aware that CBS News was producing the episode,” because CBS 23 News spent seven months compiling the segment and contacted Allegiant several times. Id. at 3. 1 Because of this alleged insider trading, the SAC asserts claims for breach of fiduciary duty and 2 unjust enrichment against Gallagher, Anderson, Sheldon, Redmond, and Ellmer. 3 After the 60 Minutes segment was announced, “shares of Allegiant stock fell $18.85 per 4 share, or over 11.4%.” Id. at 4. The plaintiffs allege that Allegiant’s safety problems have

5 subjected the company to three lawsuits, including a class action in the District of Nevada 6 alleging federal securities violations, Brendon v. Allegiant Travel Co.,2 “which is pending final 7 approval of a $4 million settlement.” Id. 8 The other misconduct alleged by the plaintiffs relates to an Allegiant proxy statement. In 9 May 2016, Gallagher, Brewer, Ellmer, Marvin, Pollard, and Redmond “issued a definitive proxy 10 statement soliciting shareholder votes” for “management proposals including the approval of the 11 Company’s 2016 Long-Term Incentive Plan” (LTIP). Id. at 34. The SAC alleges that these six 12 defendants violated Section 14 of the Securities Exchange Act of 1934 by “misrepresenting their 13 activities” related to “safety management in order to obtain shareholder approval of the 2016 14 LTIP.” Id. at 43.

15 II. ANALYSIS 16 “Devised as a suit in equity, the purpose of the derivative action was to place in the hands 17 of the individual shareholder a means to protect the interests of the corporation from the 18 misfeasance and malfeasance of faithless directors and managers.” Kamen v. Kemper Fin. Servs., 19 Inc., 500 U.S. 90, 95 (1991) (internal quotation marks and citation omitted). But “[t]o prevent 20

21 2 Under Federal Rule of Evidence 201, I take judicial notice of the order granting in part the motion to dismiss in Brendon, No. 2:18-cv-01758-APG-BNW, ECF No. 45, as well as the order 22 granting preliminary approval of the settlement in that case, ECF No. 73. Harris v. Cnty. of Orange, 682 F.3d 1126, 1131-32 (9th Cir. 2012). The defendants request that I take judicial 23 notice of three additional documents, but because I grant their motion to dismiss without considering those documents, I need not address their request. 1 abuse of this remedy,” a shareholder must “demonstrate that the corporation itself had refused to 2 proceed after suitable demand, unless excused by extraordinary conditions.” Id. at 95-96 3 (internal quotation marks and citation omitted). Accordingly, Federal Rule of Civil Procedure 4 23.1 requires that “a shareholder must either demand action from the corporation’s directors

5 before filing a shareholder derivative suit, or plead with particularity the reasons why such 6 demand would have been futile.” Arduini v. Hart, 774 F.3d 622, 628 (9th Cir. 2014). The law of 7 the state of incorporation, in this case Nevada, determines whether demand is futile. Rosenbloom 8 v. Pyott, 765 F.3d 1137, 1148 (9th Cir. 2014) (citation omitted). 9 The Supreme Court of Nevada has adopted Delaware’s two tests for demand futility from 10 Aronson v. Lewis, 473 A.2d 805 (Del. 1984), and Rales v. Blasband, 634 A.2d 927 (Del. 1993). 11 Shoen v. SAC Holding Corp., 137 P.3d 1171, 1184, 1186 (Nev. 2006), abrogated on other 12 grounds, Chur v. Eighth Judicial District Ct., 458 P.3d 336 (Nev. 2020). Aronson applies when 13 “a decision of the board of directors is being challenged in the derivative suit.” Rales, 634 A.2d 14 at 933 (emphasis omitted). Rales applies when “the board that would be considering the demand

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In Re Allegiant Travel Co. Stockholder Derivative Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-allegiant-travel-co-stockholder-derivative-litigation-nvd-2020.