Kathryn L Kircher v. Boyne USA Inc

CourtMichigan Supreme Court
DecidedMarch 27, 2025
Docket166459
StatusPublished

This text of Kathryn L Kircher v. Boyne USA Inc (Kathryn L Kircher v. Boyne USA Inc) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kathryn L Kircher v. Boyne USA Inc, (Mich. 2025).

Opinion

Michigan Supreme Court Lansing, Michigan

Syllabus Chief Justice: Justices: Elizabeth T. Clement Brian K. Zahra Richard H. Bernstein Megan K. Cavanagh Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas

This syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.

KIRCHER v BOYNE USA, INC

Docket No. 166459. Argued on application for leave to appeal December 4, 2024. Decided March 27, 2025.

Kathryn L. Kircher brought an action in the Emmet Circuit Court against Boyne USA, Inc., Stephen Kircher, and others not involved in this appeal, claiming in part that defendants breached a 2014 settlement agreement that the parties had reached after defendants fired plaintiff from their family business in 2012. The 2014 agreement provided that plaintiff would drop her claims against defendants in exchange for the right to redeem stock shares in Boyne USA at a redemption price calculated by a formula that was based in part on the amount of Boyne USA’s debt. A second settlement agreement, executed in April 2019, supplemented the first agreement and settled a different lawsuit between plaintiff and defendants. Under that settlement agreement, the parties agreed to specific redemption prices for years 2015 through 2018 as calculated by the formula from the May 2014 settlement agreement, but the redemption price for plaintiff’s 2019 shares was listed as “to be determined” because it hinged on Boyne USA’s 2018 financial statements, which defendants stated had yet to be completed when the parties perfected the April 2019 settlement agreement. Because of this uncertainty, the parties agreed that the value of plaintiff’s 2019 shares would again be determined using the formula from the 2014 settlement agreement. In 2018, Boyne USA borrowed approximately $300 million to purchase resort properties and other assets, which reduced plaintiff’s 2019 redemption price to a negative number under the formula. Upon discovering the negative redemption price, plaintiff sued defendants for breach of contract, alleging that defendants had breached the 2014 settlement agreement and acted in bad faith by refusing to use an alternative method to calculate the redemption price. Defendants moved for summary disposition under MCR 2.116(C)(8), and the trial court, Roy C. Hayes III, J., denied the motion, ruling that there were questions of fact regarding whether plaintiff could succeed on a theory that defendants had breached the implied covenant of good faith and fair dealing. Defendants applied for leave to appeal. After granting the application, the Court of Appeals, RICK, P.J., and SHAPIRO and YATES, JJ., affirmed, holding that plaintiff stated a cognizable breach-of- contract claim as to defendants’ alleged bad faith in declining to use a different redemption-price formula, given that the settlement agreement allowed the parties to depart from the formula if they agreed to do so. ___ Mich App ___ (November 2, 2023) (Docket No. 360821). Defendants sought leave to appeal in the Supreme Court, which scheduled and heard oral argument on the application regarding (1) whether the implied covenant of good faith and fair dealing applies only as an interpretive tool to understand the express terms of a contract, (2) whether plaintiff stated a valid claim for breach of contract based on the defendants’ entering into a transaction that significantly added to the debt of Boyne USA, and (3) whether plaintiff stated a valid claim for breach of contract based on the defendants’ refusal to negotiate an alternative formula to calculate the redemption price of the plaintiff’s shares. 513 Mich 1054 (2024).

In a unanimous per curiam opinion, the Supreme Court, in lieu of granting leave to appeal, held:

The Court of Appeals erred by holding that plaintiff stated a valid claim for breach of contract based on defendants’ refusal to negotiate an alternative formula to calculate the redemption price of plaintiff’s shares. Under existing precedent, the implied covenant of good faith and fair dealing does not give rise to an independent cause of action, and it does not override or replace any express contractual term. To the extent the Court of Appeals held otherwise, its judgment was reversed.

1. In this case, the Court of Appeals relied on the implied covenant of good faith and fair dealing, which has been described as a promise that neither party will do anything that will have the effect of destroying or injuring the other party’s right to receive the fruits of the contract. The Court of Appeals had previously held, however, that there is no independent cause of action for breach of the implied covenant of good faith and fair dealing, instead viewing this implied covenant as an interpretive tool with which to evaluate contractual obligations or other statutory duties. Under existing law, the implied covenant of good faith and fair dealing neither overrides nor replaces any express contractual term.

2. Applying the principles previously established regarding the implied covenant of good faith and fair dealing to the present case foreclosed plaintiff’s breach-of-contract claim. At the outset, no party made calculating the redemption price of plaintiff’s shares a matter of its own discretion; instead, the parties agreed to use a negotiated formula that unambiguously tied plaintiff’s redemption price to Boyne USA’s earnings and debt, and that agreed-upon formula governed the “to be determined” redemption price of plaintiff’s 2019 stock shares. Because the parties unmistakably expressed their respective rights regarding redemption-price calculation, the Court of Appeals erred by holding that defendants were contractually obligated to use a different formula under the implied covenant of good faith and fair dealing. The phrase “unless otherwise agreed by the Parties” in the 2014 settlement agreement did not change this conclusion. Instead, this phrase merely permitted the parties to amend the contract at a future date, reflecting the bedrock principle that parties to a contract always have the ability to mutually modify their existing agreements after the original contract has been executed. If parties to a contract forgo such a modification opportunity, the terms of the existing contract govern. The Court of Appeals’ holding effectively transformed the implied covenant of good faith and fair dealing into an independent cause of action that may be asserted in the absence of an underlying contractual duty or obligation. Because this surpassed the scope of the implied covenant as laid out in Court of Appeals precedent, the panel erred by holding that plaintiff stated a valid claim for breach of contract on that basis.

Court of Appeals judgment reversed in part, leave to appeal denied in part, and case remanded to the Emmet Circuit Court for further proceedings.

Justice THOMAS did not participate because the Court considered this case before she assumed office. Michigan Supreme Court Lansing, Michigan

OPINION Chief Justice: Justices: Elizabeth T. Clement Brian K. Zahra Richard H. Bernstein Megan K. Cavanagh Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas

FILED March 27, 2025

STATE OF MICHIGAN

SUPREME COURT

KATHRYN L. KIRCHER,

Plaintiff-Appellee,

v No. 166459

BOYNE USA, INC., and STEPHEN KIRCHER,

Defendants-Appellants, and

JOHN E. KIRCHER and AMY KIRCHER WRIGHT,

Defendants.

BEFORE THE ENTIRE BENCH (except THOMAS, J.)

PER CURIAM. In this case, plaintiff and defendants agreed to use a formula to calculate the

redemption price of plaintiff’s stock shares in defendant Boyne USA, Inc. After that formula produced a negative redemption price, plaintiff sued defendants, alleging that

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Kathryn L Kircher v. Boyne USA Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kathryn-l-kircher-v-boyne-usa-inc-mich-2025.