Kurian v. SNAPS Holding Company

CourtDistrict Court, D. Nevada
DecidedApril 21, 2020
Docket2:19-cv-01757
StatusUnknown

This text of Kurian v. SNAPS Holding Company (Kurian v. SNAPS Holding Company) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kurian v. SNAPS Holding Company, (D. Nev. 2020).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 * * *

4 THOMAS K. KURIAN, an individual, Case No. 2:19-cv-01757-GMN-EJY

5 Plaintiff, ORDER 6 v.

7 SNAPS HOLDING COMPANY, a North Dakota domestic corporation, 8 Defendant. 9 10 Before the Court is Plaintiff Thomas K. Kurian’s Motion for Leave to Amend Complaint to 11 Add Parties (ECF No. 17). The Court has considered Plaintiff’s Motion, Defendant SNAPS Holding 12 Company’s (“SNAPS”) Response (ECF No. 19), and Plaintiff’s Reply (ECF No. 21). The Court 13 finds as follows. 14 I. BACKGROUND 15 This case commenced in the Eighth Judicial District Court for Clark County, Nevada, in June 16 2019, and was subsequently removed to this Court based on diversity jurisdiction, which is not 17 threatened by the proposed First Amended Complaint (“FAC”) as the added party remains 18 completely diverse from all other parties. In his Motion, Plaintiff argues that (i) the request to amend 19 is timely under the Scheduling Order (ECF No. 15), (ii) Fed. R. Civ. P. 15(a)(2) provides a liberal 20 standard for amendment, (iii) “the Supreme Court of North Dakota … concluded ‘SNAPS exercises 21 total control over the management and activities of IDA [of Moorhead Corporation (“IDA”)] and 22 was the alter ego of IDA’”;1 and (iv) adding IDA as a defendant is proper because IDA is the alter 23 ego of SNAPS. 24 In the facts section of the FAC Plaintiff alleges, in sum, that (i) IDA “is the alter ego of 25 SNAPS who exercises total control over the management and activities of IDA;” (ii) IDA, as the 26 alter ego of SNAPS, breached a Spectrum Manager Lease Agreement (the “Agreement”) by failing

27 1 The case Plaintiff attaches to its Motion is SNAPS Holding Company v. Leach, 895 S.W.2d 763 (N.D. 2017), 1 to build out or provide “substantial services to two-third[s] of the leased area population … as per 2 the parties’ agreement;” (iii) SNAPS and IDA operated stations that fail “to comport with FCC 3 acceptance in violation of” the Agreement; and, (iv) “SNAPS and IDA operated Permanent Stations” 4 in a manner that put Plaintiff’s “license in danger” creating “potential legal liabilities” for Plaintiff. 5 Plaintiff then alleges that SNAPS and IDA, as its alter ego, breached the Agreement (the first cause 6 of action), interfered with Plaintiff’s prospective economic opportunity (the third cause of action), 7 and breached the covenant of good faith and fair dealing (the fourth cause of action). Plaintiff further 8 seeks injunctive relief (the sixth cause of action), and asserts a cause of action titled “Alter Ego 9 Piercing the Corporate Veil (the seventh cause of action). Plaintiff’s second cause of action for 10 fraud/misrepresentation states that “SNAPS induced Plaintiff to enter into an agreement with 11 SNAPS by making false representations as to its true intentions surrounding the Agreement” and 12 that therefore SNAPS and its alter ego, IDA, have injured Plaintiff. Plaintiff’s fifth cause of action 13 for declaratory relief states only that there exists “an actual, real and substantial controversy … 14 between Plaintiff[] and “Defendant ….” ECF No. 17-1. 15 In opposition, SNAPS argues that Plaintiff fails to assert facts sufficient to assert any claim 16 against IDA and the single assertion of alter ego does not save the FAC from this fatality. SNAPS 17 points out that the Agreement is between Plaintiff and SNAPS only and that the FAC should be 18 denied as futile. 19 II. DISCUSSION 20 Whether Plaintiff’s separate cause of action title “Alter Ego Piercing the Corporate Veil” is 21 a claim or a remedy is not an issue the Court reaches in this Order because, for the reasons stated 22 below, Plaintiff’s proposed FAC fails to state sufficient facts upon which an alter ego claim or 23 remedy could be granted. 24 Rule 15(a)(2) of the Federal Rules of Civil Procedure is liberally construed and amendment 25 of a complaint should be granted “when justice so requires.” Id.; Eminence Capital, LLC v. Aspeon, 26 Inc., 316 F.3d 1048, 1051 (9th Cir. 2003). However, when a proposed amendment is futile, 27 1 amendment is properly denied. Gardner v. Martino, 563 F.3d 981, 990 (9th Cir. 2009). That is, a 2 court may dismiss a cause of action for “failure to state a claim upon which relief can be granted.” 3 Fed.R.Civ.P. 12(b)(6). 4 A properly pled claim must include “[a] short and plain statement of the claim showing that 5 the pleader is entitled to relief.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). While 6 Federal Rule of Civil Procedure 8 does not require detailed factual allegations, the Rule demands 7 more than “labels and conclusions” or a “formulaic recitation of the elements of a cause of action.” 8 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation omitted). “Factual allegations must be enough 9 to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. Thus, to state a 10 claim and survive a motion to dismiss, the complaint must allege sufficient facts to “state a claim to 11 relief that is plausible on its face.” Iqbal, 556 U.S. at 678 (citation omitted). 12 In Iqbal, the Supreme Court outlined the two-step approach district courts apply when 13 considering motions to dismiss—that is, whether a party has stated a claim upon which relief may 14 be granted. First, the Court must accept as true all well-pled factual allegations in the complaint, 15 while legal conclusions are not entitled to the same assumption of truth. Id. Mere recitals of the 16 elements of a cause of action, supported only by conclusory statements, are insufficient to meet this 17 standard. Id. Second, the Court must consider whether the factual allegations in the complaint allege 18 a plausible claim for relief. Id. at 679. A claim is facially plausible when the plaintiff's complaint 19 alleges facts that allows the Court to draw a reasonable inference that the defendant is liable for the 20 alleged misconduct. Id. at 678. Where the complaint does not “permit the court to infer more than 21 the mere possibility of misconduct, the complaint has alleged, but it has not shown, that the pleader 22 is entitled to relief.” Id. at 679 (internal quotations and alterations omitted). When the allegations 23 in a complaint have not crossed the line from conceivable to plausible, plaintiff's claim must be 24 dismissed. Twombly, 550 U.S. at 570; see also Starr v. Baca, 652 F.3d 1202, 1216 (9th Cir.2011) 25 (“First, to be entitled to the presumption of truth, allegations in a complaint or counterclaim may not 26 simply recite the elements of a cause of action, but must contain sufficient allegations of underlying 27 facts to give fair notice and to enable the opposing party to defend itself effectively. Second, the 1 factual allegations that are taken as true must plausibly suggest an entitlement to relief, such that it 2 is not unfair to require the opposing party to be subjected to the expense of discovery and continued 3 litigation.”). 4 Here, Plaintiff’s proposed FAC seeks to include IDA as a defendant based on the contention 5 that IDA is the alter ego of SNAPS.

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Bell Atlantic Corp. v. Twombly
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Ashcroft v. Iqbal
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Gardner v. Martino
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Lorenz v. Beltio, Ltd.
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Starr v. Baca
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Kurian v. SNAPS Holding Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kurian-v-snaps-holding-company-nvd-2020.