KOSHA, LLC v. ALFORD

CourtDistrict Court, M.D. Georgia
DecidedJuly 28, 2021
Docket4:19-cv-00172
StatusUnknown

This text of KOSHA, LLC v. ALFORD (KOSHA, LLC v. ALFORD) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KOSHA, LLC v. ALFORD, (M.D. Ga. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA COLUMBUS DIVISION

KOSHA, LLC, et al., *

Plaintiffs, *

vs. * CASE NO. 4:19-CV-172 (CDL)

CLARENCE DEAN ALFORD, et al., *

Defendants. *

O R D E R One of the Defendants in this action, Debra Vaughn Dlugolenski, against whom Plaintiffs assert only state law claims, seeks dismissal of Plaintiff’s amended complaint because it fails to state federal law claims against her co-defendants, and thus subject matter jurisdiction does not exist. Contrary to Dlugolenski’s arguments, Plaintiffs’ amended complaint does state claims under the federal securities laws against co- defendants Clarence Dean Alford, Allied Energy Services, LLC, and Augusta Waste to Energy, LLC. Accordingly, the Court has supplemental jurisdiction over the state law claims against Dlugolenski, and her motion to dismiss ((ECF No. 105) is denied. Within twenty-one days of the date of this order, the parties shall submit an amended joint proposed scheduling order. DISCUSSION Preliminarily, the Court rejects Dlugolenski’s argument that this action must be dismissed for lack of subject matter jurisdiction based on the contention that the state law claims predominate over the federal securities claims. Although Plaintiffs assert several state law claims based on the same investments that form the subject matter for the federal claims,

the availability of relief under state law does not deprive Plaintiffs of their federal forum. See, e.g., Superintendent of Ins. of State of N. Y. v. Bankers Life & Cas. Co., 404 U.S. 6, 12 (1971) (noting that if “there was a ‘sale’ of a security and since fraud was used ‘in connection with’ it, there is redress under [§] 10(b) [of the Exchange Act], whatever might be available as a remedy under state law.”). The Court acknowledges that an action “may be dismissed for lack of subject-matter jurisdiction” if the federal claim “is (1) ‘immaterial and made solely for the purpose of obtaining jurisdiction,’ or (2) ‘wholly insubstantial and frivolous.’”

Grady v. United States Gov't, 702 F. App'x 929, 930-31 (11th Cir. 2017) (per curiam) (quoting Blue Cross & Blue Shield of Ala. v. Sanders, 138 F.3d 1347, 1352 (11th Cir. 1998)) (dismissing federal claims that were so “far-fetched” and “wholly unsupported” that they were “insubstantial and frivolous”); accord Sanders, 138 F.3d at 1352 (declining to dismiss action because the plaintiff plausibly alleged a claim under federal law). But that is not the case here. As explained below, Plaintiffs claims are clearly sustainable under the federal securities laws; therefore, the Court has subject matter jurisdiction over this action. To state a claim under the federal securities laws,

Plaintiffs must allege that Defendants took certain actions in connection with the purchase or sale of a “security.” See, e.g., 15 U.S.C. § 78j(b) (making it unlawful to “use or employ, in connection with the purchase or sale of any security registered on a national securities exchange or any security not so registered . . . any manipulative or deceptive device or contrivance in contravention of such rules and regulations as the [SEC] may prescribe”). Dlugolenski argues that the notes Plaintiffs purchased were not “securities” within the meaning of the federal securities laws. Under both the Securities Act of 1933 (“Securities Act”)

and the Securities Exchange Act of 1934 (“Exchange Act”), the definition of the term “security” includes “any note.” 15 U.S.C. § 77b(a)(1); 15 U.S.C. § 78c(a)(10). The Supreme Court has instructed that “the phrase ‘any note’ should not be interpreted to mean literally ‘any note,’ but must be understood against the backdrop of what Congress was attempting to accomplish in enacting the Securities Acts”—regulating investments. Reves v. Ernst & Young, 494 U.S. 56, 63 (1990). Still, “a note is presumed to be a ‘security,’ and that presumption may be rebutted only by a showing that the note bears a strong resemblance” to one of the following enumerated categories of instrument: (1) “the note delivered in consumer financing,” (2) “the note secured by a mortgage on a home,” (3)

“the short-term note secured by a lien on a small business or some of its assets,” (4) the note evidencing a ‘character’ loan to a bank customer,” (5) “short-term notes secured by an assignment of accounts receivable,” (6) “a note which simply formalizes an open-account debt incurred in the ordinary course of business,” or (7) a note “evidencing loans by commercial banks for current operations.” Id. at 65, 67. Here, Dlugolenski does not contend that the security notes purchased by Plaintiffs closely resemble any of these examples, and the Court finds that they do not. Even if a note lacks similarity to one of the enumerated

categories, the courts apply four factors in deciding whether a transaction involves a “security.” Id. at 66-67. Those factors are: (1) “the motivations that would prompt a reasonable seller and buyer to enter into it,” (2) the distribution plan for the instrument, (3) “the reasonable expectations of the investing public,” and (4) “whether some factor such as the existence of another regulatory scheme significantly reduces the risk of the instrument, thereby rendering application of the Securities Acts unnecessary.” Id. at 66-67. “Failure to satisfy one of the factors is not dispositive; they are considered as a whole.” S.E.C. v. Thompson, 732 F.3d 1151, 1160 (10th Cir. 2013) (quoting S.E.C. v. Wallenbrock, 313 F.3d 532, 537 (9th Cir. 2002)). In Reves, the Supreme Court examined the four factors

and determined that demand notes issued by an agricultural cooperative were “securities” because (1) the cooperative sold the notes in an effort to raise capital for general business operations and purchasers bought them to earn a profit in the form of interest, (2) although the notes were not traded on an exchange, they were “offered and sold to a broad segment of the public,” (3) the advertisements for the notes characterized them as “investments,” and (4) there were no risk-reducing factors such as insurance, collateral, or applicable regulatory scheme. Reves, 494 U.S. at 67-69. Here, Plaintiffs allege that they purchased security notes

from Allied as investments in Allied’s waste-to-energy and solar projects, with the expectation of making a significant profit. Thus, the Court finds that the first factor puts the security notes in the category of a security. See id. at 66 (“If the seller’s purpose is to raise money for the general use of a business enterprise or to finance substantial investments and the buyer is interested primarily in the profit the note is expected to generate, the instrument is likely to be a ‘security.’”). The second factor to be considered is whether the notes were “offered and sold to a broad segment of the public.” Id. at 68. Dlugolenski emphasizes that Plaintiffs allege that Defendants targeted their community for investments, not the

general investing public.

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KOSHA, LLC v. ALFORD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kosha-llc-v-alford-gamd-2021.