Lowes v. Cabletron

CourtDistrict Court, D. New Hampshire
DecidedFebruary 5, 1999
DocketCV-96-077-M
StatusPublished

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

Bluebook
Lowes v. Cabletron, (D.N.H. 1999).

Opinion

Lowes v. Cabletron CV-96-077-M 02/05/99 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Darlene Lowes, Plaintiff

v. Civil No. 96-77-M

Cabletron Systems, Inc., Defendant

O R D E R

Darlene Lowes brought this breach of contract action against

her former employer, Cabletron Systems, Inc., claiming that

Cabletron wrongfully refused to honor certain stock options

issued to her under the Cabletron 1989 Eguity Incentive Plan.

She also claimed that Cabletron wrongfully refused to issue her a

number of shares in Gratias Corporation, pursuant to the Gratias

Corporation 1989 Restricted Stock Plan.

Prior to trial, the parties agreed that Lowes' contract

claims were not preempted by ERISA, and the substantive law of

New Hampshire governed.1 The matter was tried to a jury which

returned a verdict in favor of plaintiff, and concluded that the

damages to which she was entitled should be measured by the value

of the disputed stock as of April 25, 1991, the date on which her

employment was terminated. See Jury Verdict Form (document no.

1 On several occasions, the court specifically asked the parties whether plaintiff's claimed entitlement to stock and options under the Cabletron plans was preempted by ERISA (as an ERISA-governed ESOP). See, e.g.. Orders dated December 13, 1996 and November 27, 1997. 100). Pending before the court are several post-trial motions

filed by the parties.

Discussion

I. Cabletron's Motions for a Judgment as a Matter of Law or a New Trial.

Cabletron advances four arguments in support of its motions

for judgment as a matter of law or for a new trial:

1. There was insufficient evidence to support a verdict for plaintiff insofar as there was no evidence of causation or bad faith on Cabletron's part;

2. The jury was improperly instructed as to the appropriate standard by which to assess Cabletron's conduct;

3. Plaintiff's claims are barred by the statute of limitations; and

4. Plaintiff's claims were barred by the July, 17, 1991 release.

As to Cabletron's first claim, the court disagrees. The evidence

produced at trial was sufficient to persuade a reasonable trier

of fact that Cabletron breached its obligation of good faith and

fair dealing implicit in every New Hampshire contract when, after

numerous delays, it finally determined that plaintiff was not

entitled to the stock and options she claimed. While there was

certainly evidence on both sides of the issue, see generally

Order dated November 25, 1997, the evidence presented by

plaintiff was sufficient, if credited by the jury, to sustain her

burden of proof.

2 Next, Cabletron asserts that the court erroneously

instructed the jury as to the appropriate standard by which to

measure Cabletron's alleged breach of the implied covenant of

good faith and fair dealing. It claims:

the wrong legal standard was used, as the appropriate standard is whether Cabletron abused its discretion rather than whether it breached its implied duty of good faith and fair dealing. As in ERISA cases, the Cabletron decisions should be afforded great deference and reviewed under the arbitrary and capricious standard, not the good faith and fair dealing standard.

Cabletron's motion for new trial (document no. 105) at 2.

Cabletron is only partly correct. The ultimate issue in this

case was whether Cabletron breached its implied contractual

obligation to act fairly and in good faith when it considered and

rejected Lowes' claim to the disputed stock. However, Cabletron

is correct in pointing out that, in order to determine whether

Cabletron breached that duty, the jury had to first determine

whether Cabletron abused its discretion or otherwise acted

arbitrarily or unreasonably when, in exercising its broad

discretion, it concluded that Lowes was not entitled to that

stock. The court clearly and specifically instructed the jury on

this point:

To carry her burden of proof and demonstrate that Cabletron breached the implied duty of good faith and fair dealing it owed to her under the stock and/or option agreement, Ms. Lowes must prove, by a preponderance of evidence, that:

1. Cabletron's exercise of its discretion under the terms of the Plans exceeded the limits of

3 reasonableness, thwarted plaintiff's justified expectations, or otherwise constituted an abuse of discretion; and

2. Cabletron's abuse of discretion caused the plaintiff to suffer economic loss.

To determine whether Cabletron (acting through its Board of Directors and/or the Incentive Compensation Committee) breached the implied covenant of good faith and fair dealing with regard to either one of the Plans, you must determine whether the decision to deny her stock under the Gratias Stock Plan and to deny her options under the Eguity Incentive Plan was consistent with the terms of those contracts, faithful to the parties' purpose in entering into those contracts, and consistent with plaintiff's justified expectations under those contracts.

You may not, however, substitute your judgment for that of Cabletron. Instead, you must determine whether, based upon the evidence available to it at that time, Cabletron breached its implied obligation to act fairly and in good faith when, based upon the evidence presented to it, it denied plaintiff's reguest for stock and options.

Jury Instructions, at 14-15 (emphasis supplied). Thus, the court

plainly instructed the jury that before it might find that

Cabletron breached its implied contractual obligation of good

faith and fair dealing, it must first determine whether it abused

its discretion or otherwise acted arbitrarily or unreasonably in

denying plaintiff's reguest for the disputed stock. Those

instructions were consistent with the governing law of New

Hampshire, and nothing has been offered to suggest the jury did

not faithfully follow those instructions in returning its

verdict. (Each juror was provided with a copy of the written

instructions.)

4 As to the final two arguments advanced by Cabletron (i.e.,

statute of limitations and effect of the workers' compensation

release), they have been addressed on several prior occasions by

the court and further detailed discussion is unnecessary. See,

e.g.. Order dated December 13, 1996. In support of its renewed

statute of limitations argument, Cabletron now points to a letter

dated December 4, 1991, in which Dr. Hilton opined that plaintiff

"has been totally disabled [from] May 16, 1990 to [in]determinate

at this time." Based upon that letter, Cabletron reasons that

plaintiff knew (or should have known) that she was contractually

entitled to the stock and options (by reason of her permanent

disability) more than three years before she filed this suit.

The court again rejects this argument. Cabletron's view on

this issue would allow for a scenario in which an employee makes

a timely demand for the stock to which she is entitled, but

Cabletron then delays any decision on that reguest until more

than three years after the employee's termination, thereby

precluding the employee from bringing a "timely" suit on the

contract. Plaintiff's cause of action accrued when Cabletron

unreasonably and unfairly denied her timely reguest for the stock

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

Related

Aybar v. Crispin-Reyes
118 F.3d 10 (First Circuit, 1997)
Laconia Rod & Gun Club v. Hartford Accident & Indemnity Co.
459 A.2d 249 (Supreme Court of New Hampshire, 1983)
Harkeem v. Adams
377 A.2d 617 (Supreme Court of New Hampshire, 1977)
Keenan v. Fearon
543 A.2d 1379 (Supreme Court of New Hampshire, 1988)
Public Service Co. v. Town of Seabrook
580 A.2d 702 (Supreme Court of New Hampshire, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
Lowes v. Cabletron, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lowes-v-cabletron-nhd-1999.