JGB Industries, Inc. v. Simon-Telelect, Inc. (In Re JGB Industries, Inc.)

223 B.R. 901, 1997 Bankr. LEXIS 2286, 1997 WL 998379
CourtUnited States Bankruptcy Court, E.D. Virginia
DecidedMay 1, 1997
Docket93-31491
StatusPublished

This text of 223 B.R. 901 (JGB Industries, Inc. v. Simon-Telelect, Inc. (In Re JGB Industries, Inc.)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JGB Industries, Inc. v. Simon-Telelect, Inc. (In Re JGB Industries, Inc.), 223 B.R. 901, 1997 Bankr. LEXIS 2286, 1997 WL 998379 (Va. 1997).

Opinion

MEMORANDUM OPINION

DOUGLAS O. TICE, Jr., Bankruptcy Judge.

From January 14 through 17, 1997, the court held a trial on the debtor’s amended complaint for injunctive and other relief. Having taken the matter under advisement, and for the reasons set forth in this memorandum opinion, the court (1) will dismiss the amended complaint filed by the debtor, (2) will enter a judgment declaring that the debtor is not a distributor of products, parts, or service in any territory for Simon-Telelect, Inc., and (3) will deny the request for a permanent injunction included in the counterclaim filed by Simon-Telelect, Inc.

Findings of Fact

Simon-Telelect, Inc., is a Delaware corporation with its principal place of business in Watertown, South Dakota. As the successor to Tel-E-Lect, Inc., Telelect manufactures a brand of digger derricks and aerial devices which can be attached to vehicles used in the electric power and telephone industries. The debtor is a Virginia corporation which assembles utility trucks by mounting derricks and aerial devices on chassis with custom bodies.

At some time during the mid-1940s, the two companies orally agreed that the debtor would serve as the sole distributor of Telelect products in Virginia, West Virginia, the District of Columbia, Maryland, and North Carolina. By 1975, however, both the debtor and another Telelect distributor (Altec) had begun manufacturing their own lines of digger derricks and aerial devices. Finding this to have caused a “serious conflict of business *903 interests,” Teleleet severed its relationship with both companies by letters dated August 25, 1975. Pursuant to the “terms of separation” imposed by Teleleet, the debtor retained the right to sell replacement parts through December 31, 1975, and the right to promote and to sell Teleleet products through October 31,1975. Teleleet, however, reaffirmed its right to establish new distributor outlets in the debtor’s territory as of September 1,1975.

Upon receipt of the August 25,1975, letter, the debtor contacted Teleleet in the hope of reaching a settlement. In return for the debtor ceasing to manufacture the competing line of derricks and aerial devices, and in light of the debtor’s efforts to improve its organizational structure and its sales force, Teleleet agreed in November 1975 to reappoint the debtor as a distributor both in its old territory and in the states previously serviced by Altec. Less than a year later, however, Teleleet unilaterally rescinded the authority for the debtor to operate in eastern Kentucky and eastern Tennessee.

Throughout this period, only an unsigned general policy statement issued and revised by Teleleet had governed the parties’ business relationship. Teleleet, however, concluded that a binding contract with the debt- or was needed. In a letter to the debtor dated October 6,1976, Teleleet stated:

In the absence of a formal distributor agreement, we desire this transmittal to serve the purpose of territory and term identification for the immediate time until the Agreement reaches you.
Effective immediately:
A) Tel-E-Lect hereby grants to Baker Equipment Engineering Co Inc, and Baker hereby accepts a non-exclusive, non-transferable franchise to market and distribute Tel-E-Lect products commonly referenced to as “digger/derricks” and “aerial devices”, [sic ]
B) Tel-E-Lect will not appoint another Distributor for said products or related parts and. accessories for the “utility market” (or related support groups such as contractors) within the following territories: the states of Ohio, Pennsylvania, New York, New Jersey, Delaware, Maryland, District of Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia and Florida.
C)The duration of this distributorship shall be one year initially. If the distributor performs well, it shall be extended annually by exchange of letters of intent by both parties.
Tel-E-Lect reserves the right to terminate this agreement by ninety (90) days written notice if Baker fails to comply with the terms of this agreement, attempt [sic ] to assign any of his rights or obligations, becomes financially unstable, [sic ]
It is probable this terminology will vary slightly in the formal agreement which will include other legal insertions however, the territory, duration and product line assignment will remain as stated, [sic ]
Thank you and may we together become the strongest utility force in sales and service in the East.

Over the course of the next several months, the parties exchanged revised drafts of the form of agreement which Teleleet had forwarded to the debtor. In the end, however, they could not agree on all the terms. The subject eventually was dropped with no written contract ever executed.

Nevertheless, by letters dated September 23, 1977, and November 1, 1978, the debtor shared with Teleleet its intent to extend their relationship for another year. Although Tel-elect never replied to these overtures specifically, the parties continued to conduct business as they had in the past. For each sale made, the debtor would submit a written purchase order to Teleleet which included design specifications for the equipment requested, a preferred delivery date, and the price as listed in a guide supplied and occasionally revised by Teleleet. Teleleet, in turn, would acknowledge receipt of the order and would invoice the debtor on the later of the date the product was completed or the “due date” specified in the purchase order. The debtor then would engage a carrier to ship the equipment from the Teleleet facility in Watertown.

This arrangement proceeded smoothly until 1990, when the debtor began to experience *904 both operational and financial troubles. Notwithstanding a series of structural reorganizations, design errors and inventory control problems continued to plague the debtor, and delays in delivery became more and more frequent. The financial repercussions were significant. The debtor posted losses in excess of $680,000 for fiscal year 1990, $580,000 for fiscal year 1991, and $3.5 million for fiscal year 1992.

To make matters worse, Congress in 1992 had enacted the Energy Policy Act in an effort to de-regulate the utility market. The prospect of heightened competition persuaded many electric and other power companies to defer orders until the impact of the new law could be assessed. This decision rippled throughout the industry and caused both distributors and suppliers to witness a dramatic drop in revenue. Telelect and the debtor were hit particularly hard. Telelect equipment, with its reputation for premium quality and a high price tag, began to rapidly lose market share to more modest products with a lower cost.

During the second half of 1993, Telelect and the debtor took significant steps to remedy both their respective and their common crises. In September of that year, the debt- or engaged a general management consulting firm named Princeton Associates to perform a “diagnostic” on the company.

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Bluebook (online)
223 B.R. 901, 1997 Bankr. LEXIS 2286, 1997 WL 998379, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jgb-industries-inc-v-simon-telelect-inc-in-re-jgb-industries-inc-vaeb-1997.