In re: Wells Fargo & Company Stockholder Derivative Litigation

CourtDistrict Court, N.D. California
DecidedFebruary 4, 2022
Docket3:20-cv-08750
StatusUnknown

This text of In re: Wells Fargo & Company Stockholder Derivative Litigation (In re: Wells Fargo & Company Stockholder Derivative Litigation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Wells Fargo & Company Stockholder Derivative Litigation, (N.D. Cal. 2022).

Opinion

1 2 3 4 IN THE UNITED STATES DISTRICT COURT 5 FOR THE NORTHERN DISTRICT OF CALIFORNIA 6 7 IN RE WELLS FARGO & COMPANY Case No. 20-cv-08750-MMC STOCKHOLDER DERIVATIVE 8 LITIGATION ORDER GRANTING WELLS FARGO & 9 COMPANY'S MOTION TO DISMISS

CONSOLIDATED SHAREHOLDER 10 This Document Relates To: DERIVATIVE COMPLAINT PURSUANT TO RULE 23.1 11 ALL ACTIONS

12 13 Before the Court is nominal defendant Wells Fargo & Company’s (“Wells Fargo” or 14 “the Company”) motion, filed June 22, 2021, to dismiss the Verified Consolidated 15 Shareholder Derivative Complaint pursuant to Rule 23.1 of the Federal Rules of Civil 16 Procedure. (See Dkt. No. 59.) Defendants Celeste A. Clark (“Clark”), Theodore F. 17 Craver Jr. (“Craver”), Wayne M. Hewett (“Hewett”), Donald M. James (“James”), Maria R. 18 Morris (“Morris”), Charles H. Noski (“Noski”), C. Allen Parker (“Parker”), Richard B. Payne 19 Jr. (“Payne”), Juan A. Pujadas (“Pujadas”), Ronald L. Sargent (“Sargent”), Charles W. 20 Scharf (“Scharf”), John R. Shrewsberry (“Shrewsberry”), Timothy J. Sloan (“Sloan”), and 21 Suzanne M. Vautrinot (“Vautrinot”) (collectively, “Individual Defendants”) have joined in 22 Wells Fargo’s motion. (See Dkt. Nos. 60, 62-64, 68.) Plaintiffs Timothy Himstreet, the 23 Montini Family Trust, and Clyde V. Cotton have filed opposition (see Dkt. No. 69), and 24 Wells Fargo has filed a reply in which the Individual Defendants have joined (see Dkt. 25 Nos. 72-76). The Court, having considered the papers filed in support of and in 26 opposition to the motion, rules as follows.1 27 1 BACKGROUND 2 Plaintiffs, who assert they are shareholders of Wells Fargo, allege that, in 3 response to “unlawful and pervasive sales practices that led to consumer abuses 4 spanning nearly two decades” (see Compl. ¶ 3), Wells Fargo, on February 2, 2018, 5 entered into a regulatory consent order with the Federal Reserve System (“FRS”) and, 6 thereafter, on April 20, 2018, entered into “two coordinated consent orders” with, 7 respectively, the Consumer Financial Protection Bureau (“CFPB”) and the Office of the 8 Comptroller of the Currency (“OCC”) (see Compl. ¶ 7). Plaintiffs allege the FRS consent 9 order required Wells Fargo to “improve Board oversight and remediate Wells Fargo’s 10 compliance and operational risk management policies and procedures,” and that the 11 CFPB and OCC consent orders similarly required Wells Fargo to “strengthen its 12 compliance and risk management.” (See Compl. ¶ 7.) Plaintiffs further allege that the 13 FRS consent order imposed an asset cap whereby Wells Fargo “would be restricted from 14 growing any larger than its total asset size as of the end of 2017” (see Compl. ¶ 91), and 15 that the CFPB and OCC consent orders imposed on Wells Fargo $1 billion in fines (see 16 Compl. ¶ 7). 17 According to plaintiffs, the Individual Defendants subsequently “publicly 18 represented that Wells Fargo had implemented and would continue to implement 19 meaningful corporate reforms, and that their reform efforts were in compliance with the 20 regulatory consent orders,” which “representations . . . were false.” (See Compl. ¶¶ 8-9.) 21 In particular, plaintiffs allege that, despite Wells Fargo’s obligations to meaningfully 22 address its risk and compliance programs, such programs “continued to be woefully 23 deficient” (see Compl. ¶ 9) and that Wells Fargo was so advised by the above-referenced 24 regulatory agencies (see Compl. ¶¶ 219-20). In particular, plaintiffs allege that on March 25 4, 2020, the House Committee on Financial Services reported that “Wells Fargo had 26 repeatedly failed to satisfy the terms of the consent orders” (see Compl. ¶ 218), that “the 27 1 risk management plans that Wells Fargo submitted to the FRS . . . were ‘materially 2 incomplete’ . . . despite the Company having received constant feedback and guidance 3 from the FRS” (see Compl. ¶ 219), that “Wells Fargo was informed that its plan 4 [submitted to the FRS] was ‘riddled with errors and discrepancies, such as incorrect 5 progress indicators for deliverables and illogical timeframes for achieving future 6 milestones’” (see Compl. ¶ 219), that “the OCC [had] admonished the Company’s ‘very 7 slow’ progress,” most of which “appear[ed] to come after repeated pressure by the 8 regulators, calling out missed deadlines, failed validations, and poor quality action plans” 9 (see Compl. ¶ 220), and that “the Company’s risk management infrastructure remain[ed] 10 broken and woefully inadequate to prevent future harm to consumers” (see Compl. ¶ 11 221). In addition, plaintiffs allege that, on March 10, 2020, Scharf testified before the 12 House Committee on Financial Services and “admitted that Wells Fargo ha[d] ‘not yet 13 done what is necessary to address [its] shortcomings,’ noting that the Company’s ‘culture 14 was broken.’” (See Compl. ¶ 14.) 15 Based on said allegations, plaintiffs, seeking to proceed derivatively on behalf of 16 Wells Fargo, bring claims against certain of the Individual Defendants for violation of 17 section 14(a) of the Securities Exchange Act of 1934 (“Exchange Act”) (see Compl. ¶¶ 18 284-88), and against all Individual Defendants for breach of fiduciary duty (see Compl. ¶¶ 19 289-96), waste of corporate assets (see Compl. ¶¶ 297-300), and unjust enrichment (see 20 Compl. ¶¶ 301-04). Plaintiffs also assert a claim against Sloan and Shrewsberry for 21 contribution under sections 10(b) and 21D of the Exchange Act. (See Compl. ¶¶ 305-08.) 22 DISCUSSION 23 Pursuant to Rule 23.1, a shareholder filing a derivative action to “enforce a right 24 that the corporation . . . has failed to enforce” must “state with particularity any effort . . . 25 to obtain the desired action from the directors . . . and the reasons for . . . not making the 26 effort.” See Fed. R. Civ. P. 23.1. “Although Rule 23.1 supplies the pleading standard for 27 assessing allegations of demand futility, the substantive law which determines whether 1 behalf the plaintiff is seeking relief.” Rosenbloom v. Pyott, 765 F.3d 1137, 1148 (9th Cir. 2 2014). Here, the parties agree Wells Fargo is incorporated in Delaware. 3 The Delaware Supreme Court recently adopted a three-part test as “the universal 4 test for assessing whether demand should be excused as futile.” United Food & Com. 5 Workers Union & Participating Food Indus. Emps. Tri-State Pension Fund v. Zuckerberg, 6 262 A.3d 1034, 1058 (Del. 2021). Under said test, courts, when evaluating allegations of 7 demand futility, must ask, “on a director-by-director basis,” see id. at 1059, as well as on 8 a “claim-by-claim basis,” see Oswald v. Identiv, Inc., 2018 WL 1783838, at *2 (N.D. Cal. 9 Apr. 13, 2018), aff'd sub nom. Oswald on Behalf of Identiv, Inc. v. Humphreys, 806 F. 10 App'x 577 (9th Cir. 2020), the following: 11 (i) whether the director received a material personal benefit from the alleged misconduct that is the subject of the litigation demand; 12 (ii) whether the director faces a substantial likelihood of liability on any of the claims that would be the subject of the litigation demand; and 13 (iii) whether the director lacks independence from someone who received a material personal benefit from the alleged misconduct that would be the 14 subject of the litigation demand or who would face a substantial likelihood of 15 liability on any of the claims that are the subject of the litigation demand. 16 Zuckerberg, 262 A.3d at 1059. “If the answer to any of the questions is ‘yes’ for at least 17 half of the members of the demand board[2], then demand is excused as futile.” Id.

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In re: Wells Fargo & Company Stockholder Derivative Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-wells-fargo-company-stockholder-derivative-litigation-cand-2022.