JTH Tax, LLC v. Pitcairn Franchise Development, LLC

CourtDistrict Court, E.D. Virginia
DecidedJuly 27, 2021
Docket2:21-cv-00135
StatusUnknown

This text of JTH Tax, LLC v. Pitcairn Franchise Development, LLC (JTH Tax, LLC v. Pitcairn Franchise Development, LLC) is published on Counsel Stack Legal Research, covering District 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
JTH Tax, LLC v. Pitcairn Franchise Development, LLC, (E.D. Va. 2021).

Opinion

FILED IN THE UNITED STATES DISTRICT COURT | aera | FOR THE EASTERN DISTRICT OF VIRGINIA Norfolk Division CLERCUS-DRTAGT □□□□ JTH TAX LLC d/b/a LIBERTY TAX SERVICE, Plaintiff, v. CIVIL ACTION NO. 2:21¢ev135 PITCAIRN FRANCHISE DEVELOPMENT, LLC, Defendant. MEMORANDUM OPINION AND ORDER Before the Court are two motions: Petitioner JTH Tax LLC d/b/a Liberty Tax Service’s (‘Petitioner” or “Liberty”) Motion to Confirm the Arbitration Award (“Motion to Confirm”) and Respondent Pitcairn Franchise Development, LLC’s (“Respondent” or “Pitcairn’”) Motion to Vacate the Arbitration Award (“Motion to Vacate”). ECF Nos. 3 and 14. Both the Motion to Confirm and the Motion to Vacate have been fully briefed before the Court. See ECF Nos. 4, 8, 12, 15, 17, 19. On July 1, 2021, the Court held a remote hearing on the parties’ motions. ECF No. 21. Accordingly, this matter is ripe for judicial determination. For the reasons stated below, Petitioner’s Motion to Confirm is GRANTED and Respondent’s Motion to Vacate is DENIED. I. FACTUAL AND PROCEDURAL BACKGROUND On February 5, 2021, Arbitrator Peter B. Kupelian issued a Final Arbitration Order, finding in favor of Petitioner on the parties’ cross-motions for summary judgment. See Final Arbitration Order, ECF No. 1-3. Because the parties do not dispute the facts but merely disagree with the arbitrator’s application of the facts, the Court adopts the factual and procedural background therein. Relevant facts from the Final Arbitration Order, in addition to subsequent procedural

developments, are restated below. A. Procedural Background On December 12, 2017, Pitcairn filed a motion for a temporary restraining order and preliminary injunction in the United States District Court for the Eastern District of Virginia. M. for Temp. Restraining Ord. and Prelim. Inj., Pitcairn Franchise Development LLC v. JTH Tax, Inc., No. 2:17-cv-640 (E.D. Va. Dec. 12, 2017) (ECF No. 3). In that case, Pitcairn sought to enjoin Liberty from terminating a December 31, 2007 Area Development Agreement (the “2007 ADA”) between Liberty and Peter Ziolkowski (“Ziolkowski”). The Court ordered that the ADA remain in effect but directed Pitcairn to apply to the American Arbitration Association (“AAA”) for emergency relief. Case No. 2:17-cv-640, ECF No. 16. Pitcairn later filed its initial demand with the AAA and sought a preliminary injunction to toll expiration of the 2007 ADA until there was a decision on the merits in the arbitration. □□□□□ Arbitration Order, ECF No. 1-3 at 2. The arbitrator granted the preliminary injunction on January 19, 2018. /d. Throughout arbitration, the parties continued negotiations and Pitcairn and Liberty continued to perform their 2007 ADA contractual obligations for over three years. /d. On September 29, 2020, Pitcairn filed its Amended Demand in Arbitration (the “Amended Demand”). Jd. The Amended Demand asserted two claims: (1) a claim for declaratory judgment that “[Pitcairn] is entitled to renew upon the same or similar terms as the Old Agreement, for a term of 10 years” and (2) a claim for “Failure to Pay Royalties On Ancillary Services.” /ed/. In the Final Arbitration Order, the arbitrator denied relief for both claims. /d. at 15. To enforce the Final Arbitration Order, Liberty filed the Petition for Confirmation of Arbitration and its Motion to Confirm on March 12, 2021. ECF Nos. 3 and 4. Respondent opposed

the Motion to Confirm on March 26, 2021, relying, in part, on an improper venue claim.! ECF No. 8. Petitioner replied on April 1, 2021. ECF No. 12. On May 4, 2021, Respondent separately filed its Motion to Vacate. ECF No. 14. Petitioner opposed the Motion to Vacate on May 18, 2021. ECF No. 17. Respondent replied on May 24, 2021. ECF No 19. On July 1, 2021, the Court held a virtual hearing on the parties’ motions. ECF No. 21. B. Relevant Provisions of the 2007 ADA On approximately December 31, 2007, Ziolkowski and Liberty signed the 2007 ADA—a contract for the creation and maintenance of Liberty’s tax return preparation franchises throughout the District of Columbia, Maryland, Virginia, and West Virginia. ECF No. 1-1. CEO John Hewitt executed the ADA on behalf of Liberty. /d. On August 25, 2014, Pitcairn, Ziolkowski (Pitcairn’s managing member), and Liberty executed the Assignment and Amendment to Area Developer Agreements whereby the 2007 ADA was amended and assigned from Ziolkowski to Pitcairn, a Michigan limited liability company.? ECF No. 17-2. The 2007 ADA lists a number of services Pitcairn would provide to Liberty Tax. ECF No. 1-1. These services include, but not limited to, a “Minimum Area Developer Performance” for development of Pitcairn’s Franchise Territories. /d.; 2007 ADA§ 4.1, Sch. B. The provision states, “deletion is Liberty Tax’s sole remedy for failure to meet Minimum Requirements.” /d. In exchange for Pitcairn providing specified services, Liberty Tax agreed to pay Pitcairn 50% of Royalties franchisees in Pitcairn’s territory paid

' The Court finds venue in the Eastern District of Virginia proper based upon determinations made by a District Court sitting in the Eastern District of Michigan wherein Pitcairn asserted an identical venue argument. See Ord. Granting Deft’s M. to Tr. Venue, Pitcairn Franchise Development, LLC v. JTH Tax LLC, No. 2:21-cv-10550-SFC-KGA (E.D. Mich. May 25, 2021) (ECF No. 20). There, Pitcairn filed a request for temporary restraining order and preliminary injunction based upon the same facts adjudicated at arbitration and resolved in the Final Arbitration Order. /d. at ECF No. [-1. On May 25, 2021, the Eastern District of Michigan transferred venue for that case to this Court. ? Therefore, for the sake of simplicity, the Court will refer to Pitcairn as a party to the ADA.

to Liberty Tax. /d. §3.3. The term of the 2007 ADA was ten years from the Effective Date of December 31, 2007. /d. §8.1. Much of the parties’ dispute spawns from the applicability of a renewal provision in the ADA. The renewal provision states: Upon completion of the Term of this Agreement, provided Area Developer is in compliance with the terms and conditions in this Agreement, Liberty will provide Area Developer with the right to enter into a new agreement with Liberty for the provision of services to Liberty similar to those in this Agreement. If Area Developer wishes to renew this Agreement, Area Developer must notify Liberty in writing at least 180 days before the expiration of thisAgreement. There will be no fee for the renewal, but Area Developer must execute a general release of all claims it may have against Liberty. Area Developer may also renew future Area Developer Agreements, if Area Developer is in compliance with the terms and conditions in such agreements, meets the other conditions therein for renewal, and renews by signing our then current Area Developer Agreement. The fees and percentages described in paragraphs 3.2 and 3.3 above will not be reduced upon any renewal nor will the Territory be reduced, except as may be reduced due to failure to meet Minimum Requirements, as described in paragraph 4.1 above. at § 8.2 (emphasis added). The arbitrator found that, “Pitcairn failed to provide written notice of its intent to renew” despite there being a 180-day notice requirement for renewal. Section 4.1 of the ADA states as follows: 4.1 Minimum Requirements. ... If Area Developer does not meet the Minimum Requirement, then within ninety (90) days after the end of the year in which the Minimum Requirement was not met, Liberty may notify Area Developer that it desires to delete from the Territory up to the number of Franchise Territories by which Area Developer failed to meet the Minimum Requirement for that year. Liberty’s notice will designate which of the Franchise Territories it desires to delete from the Territory, and Liberty shall have the sole discretion to determine which then unassigned (meaning unsold) Franchise Territories it chooses to delete.

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Bluebook (online)
JTH Tax, LLC v. Pitcairn Franchise Development, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jth-tax-llc-v-pitcairn-franchise-development-llc-vaed-2021.