Lamkin Wealth Management, LLC v. Rod Brooks

CourtCourt of Appeals of Kentucky
DecidedNovember 2, 2023
Docket2023 CA 000271
StatusUnknown

This text of Lamkin Wealth Management, LLC v. Rod Brooks (Lamkin Wealth Management, LLC v. Rod Brooks) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lamkin Wealth Management, LLC v. Rod Brooks, (Ky. Ct. App. 2023).

Opinion

RENDERED: NOVEMBER 3, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0271-MR

LAMKIN WEALTH MANAGEMENT, LLC AND MARK LAMKIN APPELLANTS

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE JULIE KAELIN, JUDGE ACTION NO. 20-CI-002389

ROD BROOKS APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, JONES, AND MCNEILL, JUDGES.

COMBS, JUDGE: In this breach of contract and tort action Lamkin Wealth

Management, LLC, a financial services firm, and Mark Lampkin, the firm’s

founder and a financial advisor, appeal the summary judgment of the Jefferson

Circuit Court entered on January 30, 2023, in favor of Rod Brooks, a financial

advisor formerly affiliated with Lamkin Wealth Management, LLC. After our

review, we affirm. In 2006, before he had completed his licensing exams, Brooks was

hired by Lamkin Wealth Management, LLC (Wealth Management), as an

employee of the firm. He had limited contact with the firm’s clients and was not

involved in any commission-based securities transactions. At that time, Wealth

Management was affiliated with LPL Financial Corporation, a “Registered

Investment Advisor,” that acted as a broker for Wealth Management’s securities

transactions.

Several months later, after he passed his exams, Brooks’s employment

with Wealth Management ended. He became an independent contractor sharing

revenue with Lamkin. This revenue included commissions generated from the

client accounts he serviced. Brooks became a “Registered Representative” with

LPL Financial Corporation, which now provided broker services with respect to

his clients’ securities transactions.

In October 2017, Brooks ended his association with Wealth

Management and became affiliated with another firm. Many clients chose to

continue their relationship with Brooks, and he continued to provide financial

planning services to them. His new firm was affiliated with First Allied Securities,

Inc., which provided the necessary broker services to Brooks’s clients.

On April 7, 2020, Lamkin and Wealth Management filed a civil action

against Brooks in Jefferson Circuit Court. They alleged that Brooks was “subject

-2- to and contractually bound by the policies stated in the [Wealth Management]

Employee Handbook.” They alleged that when Brooks left, he breached

provisions of the employee handbook -- including its two-weeks’-notice provision

and its non-compete provisions. They also alleged that he had likely

misappropriated confidential information regarding clients in violation of the

employee handbook provisions. Separately, they argued that Brooks tortiously

interfered with a prospective business advantage; engaged in unfair competition;

and breached his fiduciary duties to the firm and Lamkin. They sought

compensatory and punitive damages.

Brooks answered and denied the material allegations of the complaint.

As an independent contractor, he denied that he was bound by any of the terms of

their employee handbook or that he owed fiduciary duties to Lamkin or the firm.

Discovery ensued. The matter was set for a bench trial to commence in January

2023.

In October 2022, Wealth Management and Lamkin filed a motion for

partial summary judgment. Observing that the parties’ brokers were signatories to

the Protocol for Broker Recruiting, they argued that Brooks’s failure to abide by its

provisions (concerning his transition to a new firm supported by a different broker)

meant that he could not use the protocol as a shield from the litigation instituted

against him. Brooks argued that the terms of the Protocol for Broker Recruiting

-3- were absolutely immaterial to the dispute because the parties are not, never were,

and could never be signatories to the agreement.

Additionally, Brooks filed a motion for summary judgment. He

explained that his only agreement with Wealth Management or Lamkin was a split-

fee agreement. There was no allegation that the terms of this agreement had ever

been violated. He had never agreed to the terms of any non-compete provision.

As an independent contractor, he argued that he was not bound by the terms of the

firm’s employee handbook, which merely explained employee benefits and

provided “some general guidance about rules and operating procedures which are

believed to be useful to all employees.”

Brooks argued that there was no legal basis upon which to conclude

that he owed Wealth Management or Lamkin a fiduciary duty of any kind, pointing

out that he was forbidden by governing regulations from acting as a fiduciary to

anyone except his clients. He observed that financial advisors are free to change

firms; that clients can follow their financial advisors to new firms; and that

previous firms are prohibited from interfering with this process. Brooks claimed

that the allegations contained in the complaint filed by Wealth Management and

Lamkin were patently false and were subject to sanctions by the court.

In response, Wealth Management and Lamkin admitted that the

Broker Protocol was not a contract between the parties. Nevertheless, they

-4- explained that Brooks would have been “wise to follow the transition procedure it

outlines as a guarantee of protection from a lawsuit. . . .”

Furthermore, Lamkin and Wealth Management argued that summary

judgment was not warranted. They characterized as “incredible” Brooks’s

representation that he had executed a single contract -- the split fee agreement --

after he had worked with the firm for more than nine years. They argued that he

must have agreed to protect confidential information and trade secrets; that he must

have agreed not to lure clients away from the firm; and that he must have agreed

not to compete with the firm if he decided no longer to be associated with it. In

support of these statements, they presented two affidavits.

The affidavit testimony of Doug Obradovich (President of Wealth

Management) indicated that “Registered Representatives who were affiliated with

[Wealth Management] either as at-will Independent Contractors or as Employee

Advisors, were expected to sign a Non-Compete Representative Agreement.”

However, Obradovich acknowledged that the file folder related to Brooks and kept

in Obradovich’s office did not contain any such agreement. He also explained that

he had led discussions at firm meetings that focused upon the firm’s “Non-

Compete Representative Agreement” and that “the goal was to be sure everyone

understood ‘the right way to leave [Wealth Management].’” A copy of the Non-

-5- Compete Representative Agreement executed by a former associate of the firm,

Joseph Gary Smith, was attached to the affidavit.

The affidavit testimony of Joseph Gary Smith indicated that he

understood that “all the Registered Representatives were expected to sign [the

employee handbook] and “a Non-Compete Representative Agreement.” Smith

stated that when he left the firm, Lamkin told him that he “had left the right way.”

Lamkin and Wealth Management argued that “[t]hese two affidavits,

each from an experienced Registered Representative with years in the industry,

including time at [the firm], raise serious doubts about Brooks’ [sic] insistence that

he never had a contract with [Wealth Management] other than the split fee

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Lamkin Wealth Management, LLC v. Rod Brooks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lamkin-wealth-management-llc-v-rod-brooks-kyctapp-2023.