Mackie Banks v. Theodore Banks and Southern Comfort, LLC

CourtCourt of Chancery of Delaware
DecidedNovember 29, 2022
DocketCA 2022-0428-PWG
StatusPublished

This text of Mackie Banks v. Theodore Banks and Southern Comfort, LLC (Mackie Banks v. Theodore Banks and Southern Comfort, LLC) 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
Mackie Banks v. Theodore Banks and Southern Comfort, LLC, (Del. Ct. App. 2022).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE PATRICIA W. GRIFFIN CHANCERY COURTHOUSE MASTER IN CHANCERY 34 The Circle GEORGETOWN, DELAWARE 19947

Date Submitted: September 15, 2022 Final Report: November 29, 2022

Anthony N. Delcollo, Esq. Andrew L. Cole, Esq. Thomas Kramer, Esq. Cole Schotz PC Offit Kurman PA 500 Delaware Ave., Suite 1410 222 Delaware Ave., Suite 1105 Wilmington, DE 19801 Wilmington, DE 19801

Re: Mackie Banks, in her individual capacity and derivatively on behalf of the Banks Frankford Real Estates Joint Venture Partnership v. Theodore Banks and Southern Comfort, LLC and the Banks Frankford Real Estate Joint Venture Partnership, a Delaware general partnership C.A. No. 2022-0428-PWG

Dear Counsel:

Pending before me is a dispute about an oral partnership agreement between a

mother and a limited liability company managed by her son for the purpose of

developing, leasing and selling properties in Frankford, Delaware. The mother filed

a complaint alleging a derivative claim against the LLC and her son for breach of

fiduciary duties for the withholding of rental income and profits and the failure to

account, and claims for unjust enrichment and breach of contract. The son and the

LLC have moved to dismiss the complaint, asserting that the claims regarding certain

properties are barred by laches, the claims against the son fail to plead facts sufficient

to pierce the corporate veil, the unjust enrichment claim is duplicative of the breach Banks v. Banks C.A. No. 2022-0428-PWG November 29, 2022

of contract claim, and the breach of contract claim is barred by the statute of frauds.

I recommend the Court deny the motion to dismiss, except the son’s claim concerning

piercing the corporate veil. I find that the mother has not pleaded sufficient facts to

pierce the corporate veil and dismiss her claims seeking to hold the son liable for the

LLC’s actions. This is a final report.

I. BACKGROUND

Plaintiff Mackie Banks (“Mackie”) and Defendant Southern Comfort, LLC

(“LLC”), a limited liability company solely owned by Defendant Ted Banks (“Ted,”

together with the LLC, “Defendants”), Mackie’s son, allegedly entered into an oral

general partnership, the Banks Frankford Real Estate Joint Venture Partnership (“JV

Partnership”), for the development and leasing of real property in Frankford,

Delaware.1 Mackie deeded a one-half interest in property located at 17 Thatcher

Street, Frankford, Delaware (“Thatcher Property”) to Ted, as joint tenants with rights

of survivorship, with the LLC collecting rents and dividing the rental income equally

with Mackie.2 Mackie alleges that, in 2021, while they were involved in an unrelated

family dispute, Ted began to improperly withhold rental payments from her. 3 She

also asserts that she transferred ownership of three (3) lots in Frankford, Delaware

1 Docket Item (“D.I.”) 6, at 2. I use first names in pursuit of clarity and intend no familiarity or disrespect. 2 Id., at 2-3. 3 Id., at 4.

2 Banks v. Banks C.A. No. 2022-0428-PWG November 29, 2022

(“Clayton Avenue Properties”) to Ted on July 15, 2016, for a partial payment of

$100,000.00, in return for a payment of $40,000.00 upon the sale of each parcel.4 And

that she invested an additional $63,000.00 towards the preparation and subdivision of

the Clayton Avenue Properties.5 She contends that the LLC and Ted, with another

investor, completed construction of a home on one of the Clayton Avenue Properties

in 2021 and sold that lot, as well as the other two lots, without accounting to her, as

partner in the JV Partnership, for any profit.6 She alleges that the LLC and Ted

exerted complete control over the JV Partnership, excluding her from the management

and operation of the business.7

Mackie filed a complaint on May 16, 2022, and an amended complaint

(“Amended Complaint”) on June 20, 2022, alleging that the LLC and Ted breached

their fiduciary duties to the JV Partnership under 6 Del. C. § 15-404 and asserting

demand futility under 6 Del. C. § 15-405(f), were unjustly enriched at her expense,

and breached the oral partnership agreement.8 She seeks access to the partnerships’

books and records, damages, the imposition of a constructive trust, and attorneys’

4 Id. 5 Id., at 5. 6 Id. 7 See id., at 2-5, 8. 8 D.I. 1; D.I. 6. The JV Partnership is named as a nominal defendant in this action “solely in a derivative capacity.” D.I. 6, at 5-6.

3 Banks v. Banks C.A. No. 2022-0428-PWG November 29, 2022

fees.9 On July 5, 2022, Defendants filed a motion to dismiss the Amended Complaint

under Court of Chancery Rule 12(b)(6) (“Motion”), and their opening brief on August

8, 2022.10 Mackie’s answering brief was filed on August 31, 2022, and Defendants’

reply brief on September 15, 2022.11

II. STANDARD OF REVIEW

The standards governing a motion to dismiss for failure to state a claim under

Court of Chancery Rule 12(b)(6) are well settled:

(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 (iii) dismissal is inappropriate unless the plaintiff would not be entitled to recover under any reasonably conceivable set of circumstances susceptible of proof.12

“[T]he touchstone to survive a motion to dismiss is reasonable conceivability,” which

is a “minimal” and “plaintiff-friendly” standard.13 “Only if the court can say with

reasonable certainty that plaintiff could prevail on no state of facts inferable from the

9 D.I. 6, at 13. 10 D.I. 8; D.I. 11. 11 D.I. 13, D.I. 14. 12 Savor, Inc. v. FMR Corp., 812 A.2d 894, 896-97 (Del. 2002) (internal quotation marks and citations omitted). 13 Tygon Peak Cap. Mgmt., LLC v. Mobile Invs. Investco, LLC (“Tygon”), 2022 WL 34688, at *11 (Del. Ch. Jan. 4, 2022), reargument granted in part, 2022 WL 414399 (Del. Ch. Feb. 10, 2022) (internal quotation marks and citations omitted).

4 Banks v. Banks C.A. No. 2022-0428-PWG November 29, 2022

pleadings may the court dismiss a complaint at this preliminary stage.” 14 “Despite

this forgiving standard, the Court need not ‘accept conclusory allegations unsupported

by specific facts’ or ‘draw unreasonable inferences in favor of the non-moving

party.’”15 “Because a motion to dismiss under Chancery Rule 12(b)(6) must be

decided without the benefit of a factual record, the Court of Chancery may not resolve

material factual disputes; instead, the court is required to assume as true the well-

pleaded allegations in the complaint.”16

III. ANALYSIS

The Motion contends that any claims regarding the Clayton Avenue Properties

are barred by laches, claims against Ted fail to plead facts sufficient to pierce the

corporate veil, the unjust enrichment claim is duplicative of the breach of contract

claim, and the breach of contract claim is barred by the statute of frauds. 17 I address

each contention in turn.

14 In re USACafes, L.P. Litig., 600 A.2d 43, 47 (Del. Ch. 1991). 15 Tygon, 2022 WL 34688, at *11 (citations omitted). 16 Malpiede v. Townson, 780 A.2d 1075, 1082 (Del. 2001). 17 D.I. 11.

5 Banks v. Banks C.A. No.

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