In Re Summons Issued to Target Corp.

2018 NCBC 125
CourtNorth Carolina Business Court
DecidedDecember 4, 2018
Docket18-CVS-12841
StatusPublished

This text of 2018 NCBC 125 (In Re Summons Issued to Target Corp.) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Summons Issued to Target Corp., 2018 NCBC 125 (N.C. Super. Ct. 2018).

Opinion

In re Summons Issued to Target Corp., 2018 NCBC 125.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION WAKE COUNTY 18 CVS 12841

IN THE MATTER OF THE SUMMONS ISSUED TO TARGET ORDER AND OPINION CORPORATION AND AFFILIATES REGARDING DESIGNATION

1. THIS MATTER is before the Court upon North Carolina Secretary of

Revenue Ronald G. Penny’s (“Secretary”) Opposition to Notice of Designation as a

Mandatory Complex Business Case (the “Opposition”) of the above-captioned

proceeding. (Opp’n Notice Designation Mandatory Complex Business Case, ECF No.

6.)

North Carolina Department of Justice, by Andrew Owen Furuseth, for the North Carolina Secretary of Revenue.

Terpening Law PLLC, by William R. Terpening, for Target Corporation.

Bledsoe, Chief Judge.

2. The Secretary filed an Application for an Order to Enforce Summons in the

Wake County Superior Court on October 18, 2018 (the “Application”), seeking an

order compelling Target Corporation and its affiliates (“Target”) to comply with the

Secretary’s administrative summons issued on June 4, 2018, pursuant to N.C. Gen.

Stat. § 105-258(a)(4). (Application Order Enforce Summons, ECF No. 3.)

3. On November 16, 2018, Target filed a Notice of Designation of Action as

Mandatory Complex Business Case under N.C. Gen. Stat. § 7A-45.4 (“NOD”). (Notice

Designation Action Mandatory Complex Business Case [hereinafter “NOD”], ECF No.

5.) Target designated this proceeding as a mandatory complex business case under sections 7A-45.4(a)(1), permitting designation for material issues related to disputes

involving the law governing corporations, and (a)(8), permitting designation for

material issues related to disputes involving trade secrets. (NOD 1–2.)

4. This proceeding was designated a mandatory complex business case by

order of the Chief Justice of the Supreme Court of North Carolina on November 16,

2018, (Designation Order, ECF No. 1), and assigned to the Honorable Michael L.

Robinson by order of the undersigned on November 19, 2018, (Assignment Order,

ECF No. 2.)

5. On November 21, 2018, the Secretary filed the Opposition and a Motion to

Expedite Review of Designation as Mandatory Complex Business Case (the “Motion

to Expedite”). (Mot. Expedite Review Designation Mandatory Complex Business

Case, ECF No. 7.) This Court granted the Motion to Expedite on the same day and

ordered Target to file its response to the Opposition no later than November 29, 2018.

(Order Mot. Expedite Review Designation, ECF No. 9.)

6. Target timely filed its Response to Opposition to Notice of Designation as

Mandatory Complex Business Case (“Response”) on November 29, 2018. (Resp. Opp’n

Notice Designation [hereinafter “Response”], ECF No. 10.) The Opposition is now

ripe for consideration. “The Notice of Designation shall, in good faith and based on

information reasonably available, succinctly state the basis of designation . . . .” N.C.

Gen. Stat. § 7A-45.4(c). Therefore, the Court may consider all materials reasonably

necessary to rule on an opposition to designation. 7. There is no indication in either N.C. Gen. Stat. § 105-258 or § 7A-45.4 that

the General Assembly intended the Business Court to hear tax summons enforcement

proceedings. Neither statute specifically references Business Court designation for

these types of tax proceedings. This statutory silence stands in marked contrast to

the legislature’s treatment of the judicial review of contested tax cases, where the

legislature has made it clear that Business Court designation may be proper. See

N.C. Gen. Stat. § 105-241.16 (requiring such petitions be filed “in accordance with the

procedures for a mandatory business case set forth in G.S. 7A-45.4(b) through (f)”).

8. In light of the Court’s resolution of the Opposition as set forth below, the

Court does not find it necessary to determine whether tax summons proceedings

could ever be designated to the Business Court in appropriate circumstances. That

said, the Court finds the Secretary’s argument that Business Court designation would

necessarily cause unacceptable delay in contravention of the intended purpose of

section 105-258 unpersuasive. See In re Ernst & Young, LLP, 363 N.C. 612, 617, 684

S.E.2d 151, 154 (2009) (“[T]he task before the court in a summons enforcement

proceeding is summary in nature and relatively uncomplicated.”). To the contrary,

the Business Court is well-equipped to hear administrative proceedings and time-

sensitive matters in which the suspension or modification of case management

requirements may be appropriate. See N.C. Gen. Stat. § 7A-45.4(b)(1). Likewise,

contrary to the Secretary’s argument, the suspension of the Rules of Civil Procedure

in tax summons enforcement proceedings, see In re Ernst & Young, LLP, 363 N.C. at 618, 684 S.E.2d at 155, does not, without more, foreclose the Business Court from

hearing such proceedings.

9. Turning to the substantive grounds for Target’s NOD, the Court concludes

that this dispute involves neither the law governing corporations nor trade secrets,

and thus that the Opposition is well-founded.

10. First, Target argues that, in the absence of the North Carolina Rules of Civil

Procedure and other statutory direction, corporations like Target need guidance from

the Business Court to determine the procedures a taxpayer should follow in a tax

summons enforcement proceeding. (See NOD 4–5 (citing In re Ernst & Young, LLP,

363 N.C. at 617, 684 S.E.2d at 154–55); Response 8.) On this basis, Target claims the

Application raises a material issue related to a dispute involving the law governing

corporations. The Court disagrees. Section 105-258’s provisions are not limited to

corporations or other business organizations; they apply equally to individuals. Thus,

to the extent section 105-258 needs clarification, that need does not derive from a

business organization’s form or the law governing that organization. Rather the need

is one shared by all taxpayers.

11. Next, while Target alleges that the Secretary’s tax summons broadly seeks

“confidential and highly-sensitive Target documents, including Target’s trade secrets

and business information,” (NOD 4), the Application does not reflect a dispute

involving a determination of the existence of a trade secret or the misappropriation

or use of a trade secret. The Court concludes that our legislature did not intend for

the Business Court to referee discovery disputes in actions that do not otherwise qualify for Business Court designation simply because one party contends that

another party is seeking production of the first party’s trade secret information. See,

e.g., Stay Alert Safety Servs., Inc. v. Pratt, 2017 NCBC LEXIS 101, at *4–6 (N.C.

Super. Ct. Nov. 1, 2017) (finding that in an action for breach of contract, the complaint

did not raise a material dispute involving trade secrets merely because the term

“trade secret” appeared in the contractual language quoted in the complaint).

12. Finally, the Court finds that Target’s reliance on Delhaize America, Inc. v.

Lay, 2011 NCBC LEXIS 9 (N.C. Super. Ct. Jan. 12, 2011), is misplaced. Delhaize was

a civil action commenced by the taxpayer filing a complaint seeking a refund of North

Carolina corporate income tax from the Department of Revenue, not a specialized tax

summons proceeding under section 105-258. See Delhaize, 2011 NCBC LEXIS at *3.

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Related

In Re the Summons Issued to Ernst & Young, LLP
684 S.E.2d 151 (Supreme Court of North Carolina, 2009)

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