Kun Jiang v. Haslet Park Homeowners Association

CourtCourt of Chancery of Delaware
DecidedJuly 31, 2024
DocketC.A. No. 2023-0780-LM
StatusPublished

This text of Kun Jiang v. Haslet Park Homeowners Association (Kun Jiang v. Haslet Park Homeowners Association) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kun Jiang v. Haslet Park Homeowners Association, (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

KUN JIANG, ) ) Plaintiff, ) ) v. ) C.A. No. 2023-0780-LM ) HASLET PARK HOMEOWNERS ) ASSOCIATION and MASTRIANA ) PROPERTY MANAGEMENT, INC., ) ) Defendants. )

ORDER

WHEREAS:

A. On August 1, 2023, Plaintiff Kun Jiang filed this action against

Defendants Haslet Park Homeowners Association (hereinafter, “HOA”) and

Mastriana Property Management, Inc. (hereinafter, “Mastriana”) (collectively, the

“Defendants”) for a declaration that Defendants failed to 1) comply with Code of

Regulations Article VI, Section 2 and 3 related to window installation; 2) violations

of Delaware Uniform Common Interest Ownership Act (DUCIOA) by denying

access to meetings and imposing fines without a hearing process; 3) breaches of

fiduciary duties.1

1 D. I. 1 at ⁋1. B. Defendants filed a Motion to Dismiss Plaintiff’s claims under Court of

Chancery Rule 12(b)(6) on August 29, 2023.2

C. On October 10, 2023, Plaintiff responded to the Defendants’ Motion to

Dismiss.3

D. The Defendants filed their opening briefs in support of the motions to

dismiss on November 9th and 10th. 4

E. On November 29, 2023, Plaintiff filed an amended complaint against

Defendants for: (a) failure to comply with governing documents, including Code of

Regulations Article VI, Sections 2 and 3, regarding the approval process for window

installations that are not structural change or common elements; (b) violations of

Delaware Uniform Common Interest Ownership Act (DUCIOA) for denying access

to HOA board meetings, filing deed violation notices against Plaintiff’s property,

and imposing arbitrary fines without a proper hearing process; (c) breach of fiduciary

duties for arbitrary, capricious, and unreasonable actions, including self-dealing in

the HOA election; (d) Mastriana’s aiding and abetting for the breach of fiduciary

duties; (e) Defamation; (f) Civil Conspiracy; and, (g) Intentional infliction of

emotional distress.5

2 D. I. 11. 3 D. I. 12. 4 D. I. 17; D. I. 18. 5 D. I. 23 at ⁋ 1. 2 F. On December 5, 2023, Plaintiff responded to Defendants’ Motions to

Dismiss.6

G. At the request of the parties, and by order of this Court, the briefing

schedule was adjusted to allow Defendants to address Plaintiff’s Amended

Complaint and subsequent Response to the Defendants’ Motion to Dismiss, which

addressed the claims in the Amended Complaint.7

H. On January 22, 2024, the Defendants filed opening briefs on its motion

to dismiss Plaintiff’s amended complaint.8

I. On February 15, 2024, Plaintiff filed a response to Defendants’ motions

to dismiss.9

J. On March 7, 2024, Defendant Mastriana replied to the Plaintiff’s

opposition.10

K. On March 11, 2024, Defendant Haslet Park HOA replied to the

Plaintiff’s opposition. 11

6 D. I. 26; D. I. 27. 7 D. I. 29; D. I. 30. 8 D. I. 31; D. I. 34. 9 D. I. 36; D. I. 37. 10 D. I. 38. 11 Id. 3 L. That same day, Haslet Park HOA joined Mastriana, for reasons set forth

in Mastriana’s Opening Brief.12

M. On April 29, 2024, all parties agreed to forgo oral argument on the

motion to dismiss.13

N. Under Court of Chancery Rule 12(b)(6), the standard of review is

settled:

a. (i) all well-pleaded factual allegations are accepted as true; (ii)

even vague allegations are “well-pleaded” if they give the

opposing party notice of the claim; (iii) the Court must draw all

reasonable inferences in favor of the non-moving party; and

[(iv)] dismissal is inappropriate unless the “plaintiff would not

be entitled to recover under any reasonably conceivable set of

circumstances susceptible of proof.”14

IT IS HEREBY ORDERED, this 31st day of July 2024, as follows:

1. The Defendants’ Motion to Dismiss Plaintiff’s claims is GRANTED

IN PART and DENIED IN PART.

12 D. I. 39. 13 D. I. 41. 14 Savor, Inc. v. FMR Corp., 812 A.2d 894, 896–97 (Del. 2002) (footnotes omitted) (quoting Kofron v. Amoco Chems. Corp., 441 A.2d 226, 227 (Del. 1982)). 4 2. The Defendants’ Motion to Dismiss Plaintiff’s claim for breach of

contract is DENIED. I find that, in viewing factual allegations most favorably to the

Plaintiff, this claim is sufficient to potentially recover damages. Article VI Sections

2 and 3, when interpreted in conjunction with 25 Del. C. § 81-302(a)(6), are

ambiguous. A sufficient breach of contract claim only must contain “a short and

plain statement of the claim showing that the pleader is entitled to relief.” 15 To

survive a motion to dismiss in failing to state a breach of contract claim, a plaintiff

must show that a contract exists, an obligation imposed by that contract was

breached, and that this breach resulted in damages. 16 Plaintiff has surpassed these

requirements by averring that a contract between Plaintiff and Defendants exists, all

parties have obligations per the contract, and that damages are imposed for failure

to follow the contract.

3. The Defendants’ Motion to Dismiss Plaintiff’s claim for breach of

fiduciary duties is DENIED. “It is well established that the directors owe their

fiduciary obligations to the corporation and its shareholders.”17 The Defendants are

Delaware Corporations and Plaintiff is a member of the HOA. 18 The harm alleged

15 Del. Ct. Ch. R. 8. 16 VLIW Tech., LLC v. Hewlett-Packard Co., 840 A.2d 606, 612 (Del. 2003). 17 N. Am. Cath. Educ. Programming Found., Inc. v. Gheewalla, 930 A.2d 92, 99 (Del. 2007). 18 D. I. 1 at ⁋⁋2-3. 5 here is not unique to the Plaintiff and can occur to any member of the HOA.

Therefore, the harm arising from the breach here can be attributable to the

Defendants' breach of fiduciary duty.

4. The Defendants’ Motion to Dismiss Plaintiff’s claim for Management

Agent Aiding and Abetting the Breach of Fiduciary Duties is DENIED. Accepting

that the letter mailed to selected recipients before the August 8, 2023 election was

sent by Mastriana, this claim survives the motion to dismiss. 19 The four elements

required to succeed in a claim of aiding and abetting fiduciary duties are: “(i) the

existence of a fiduciary relationship, (ii) a breach of the fiduciary's duty, (iii)

knowing participation in that breach by the defendants, and (iv) damages

proximately caused by the breach.”20 As previously stated, Plaintiff has displayed

that a fiduciary duty exists and that duty has been breached. This letter explicitly

states that Plaintiff violated HOA regulations and claims that Plaintiff “has since

begun a campaign of harassment and threats in an attempt to circumvent the rules.”21

It is conceivable that this communication diminished Plaintiff’s reputation and

caused irreparable harm to Plaintiff under which he will recover.

19 D. I. 23 at ⁋59. 20 RBC Cap. Markets, LLC v. Jervis, 129 A.3d 816, 861 (Del. 2015).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kofron v. Amoco Chemicals Corp.
441 A.2d 226 (Supreme Court of Delaware, 1982)
Savor, Inc. v. FMR Corp.
812 A.2d 894 (Supreme Court of Delaware, 2002)
Spence v. Funk
396 A.2d 967 (Supreme Court of Delaware, 1978)
Allied Capital Corp. v. GC-Sun Holdings, L.P.
910 A.2d 1020 (Court of Chancery of Delaware, 2006)
VLIW TECHNOLOGY, LLC v. Hewlett-Packard Co.
840 A.2d 606 (Supreme Court of Delaware, 2003)
RBC Capital Markets, LLC v. Jervis
129 A.3d 816 (Supreme Court of Delaware, 2015)
Harold Kraft v. Wisdomtree Investments, Inc.
145 A.3d 969 (Court of Chancery of Delaware, 2016)
Organovo Holdings, Inc. v. Dimitrov
162 A.3d 102 (Court of Chancery of Delaware, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Kun Jiang v. Haslet Park Homeowners Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kun-jiang-v-haslet-park-homeowners-association-delch-2024.