Mehta v. Smurfit-Stone Container Corporation

CourtCourt of Chancery of Delaware
DecidedOctober 20, 2014
DocketCA 6891-VCL
StatusPublished

This text of Mehta v. Smurfit-Stone Container Corporation (Mehta v. Smurfit-Stone Container Corporation) 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
Mehta v. Smurfit-Stone Container Corporation, (Del. Ct. App. 2014).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

RAM MEHTA AND NEENA MEHTA, ) ) Plaintiffs, ) ) v. ) C.A. No. 6891-VCL ) SMURFIT-STONE CONTAINER ) CORPORATION, AND ITS OFFICIALS, ) ROCK-TENN COMPANY, AND ITS ) OFFICIALS, ) ) Defendants. )

MEMORANDUM OPINION

Date Submitted: September 15, 2014 Date Decided: October 20, 2014

Ram Mehta and Neena Mehta, Buena Park, California; Pro Se Plaintiffs.

William M. Lafferty, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Attorneys for Defendants.

LASTER, Vice Chancellor. Plaintiffs Ram Mehta and Neena Mehta owned common stock of Smurfit-Stone

Container Corporation (the ―Company‖ or ―Smurfit-Stone‖). In this lawsuit, they

challenge (i) decisions leading up to the Company’s bankruptcy, along with steps taken in

connection with its exit from bankruptcy, (ii) the Company’s subsequent merger with and

into Rock-Tenn CP, LLC (―Rock-Tenn Sub‖), a wholly owned acquisition subsidiary of

Rock-Tenn Company (―Rock-Tenn Parent‖), and (iii) Rock-Tenn Sub’s failure to provide

them with the merger consideration after their demand for appraisal lapsed. The

defendants have moved to dismiss the complaint for failure to state a claim on which

relief can be granted. The challenges to the stock distribution and the merger are

dismissed, but a claim against Rock-Tenn Sub for failing to provide the Mehtas with their

share of the merger consideration survives.

I. FACTUAL BACKGROUND

The facts are drawn from the verified amended complaint (the ―Complaint‖) and

the documents it incorporates by reference. Other facts are undisputed or subject to

judicial notice. The plaintiffs, as non-movants, receive the benefit of all reasonable

inferences.

A. The Bankruptcy Proceeding

Smurfit-Stone is a Delaware corporation that manufactures paperboard and paper-

based packaging. On January 26, 2009, Smurfit-Stone filed a voluntary petition in

bankruptcy under Chapter 11 of the Bankruptcy Code. By order dated June 21, 2010, the

bankruptcy court approved the Company’s plan of reorganization. In re Smurfit-Stone

1 Container Corp., Case No. 09-10235 (BLS) (Bankr. D. Del. Jun 21, 2010) (ORDER)

[hereinafter ―Confirmation Order‖].

Under the plan of reorganization, and pursuant to the Confirmation Order,

Smurfit-Stone’s existing shares were cancelled and new shares of common stock were

distributed to the Company’s creditors and stockholders. Creditors received 95.5% of the

new common stock. The common and preferred stockholders split the remainder. As part

of the plan of reorganization, Smurfit-Stone’s new board of directors approved

employment agreements for management that contemplated the payment of bonuses if

Smurfit-Stone engaged in a change-of-control transaction within a specified timeframe.

See In re Smurfit-Stone Container Corp. S’holders Litig., 2011 WL 2028076, at *2 (Del.

Ch. May 24, 2011). Significantly, the Confirmation Order discharged and released all

claims against Smurfit-Stone and its directors relating to the bankruptcy. See

Confirmation Order ¶¶ 51–55.

The Mehtas owned Smurfit-Stone common stock before the bankruptcy

proceeding. After the reorganization, the Mehtas held 1,486 shares of Smurfit-Stone

common stock.

B. The Merger With Rock-Tenn

On January 23, 2011, Smurfit-Stone and Rock-Tenn Parent announced their

intention to merge. The merger agreement called for Smurfit-Stone to merge with and

into Rock-Tenn Sub. Pursuant to the merger, each share of Smurfit-Stone common stock

would be converted into the right to receive $17.50 in cash and .30605 shares of Rock-

Tenn Parent common stock.

2 Over the next two months, stockholders pursued litigation in Delaware and Illinois

challenging the adequacy of the merger consideration. After the Illinois cases were stayed

in favor of the consolidated Delaware action, this court denied the stockholder plaintiffs’

application for a preliminary injunction. See Smurfit-Stone S’holders Litig., 2011 WL

2028076, at *1. The merger closed on May 27, 2011. The Delaware action was later

settled, and this court approved the settlement by order dated February 2, 2012 (the

―Settlement Order‖). The Settlement Order certified the Delaware action as a class action,

granted the defendants broad releases covering all possible claims arising out of or

relating to the merger, and dismissed the Delaware litigation with prejudice.

C. The Appraisal Demand

Through their broker, TD Ameritrade, the Mehtas made a timely demand for

appraisal. Because they demanded appraisal, the Mehtas did not receive the merger

consideration after the merger closed on May 27, 2011.

The Mehtas never filed a petition for appraisal. No other stockholder filed an

appraisal petition either. The 120-day time period—during which at least one stockholder

must file an appraisal petition for an appraisal proceeding to move forward—came and

went on September 24, 2011.

The Mehtas withdrew their demand for appraisal in writing on March 16, 2012,

long after the time for filing an appraisal petition had run. From that point on, the Mehtas

communicated repeatedly with TD Ameritrade, the defendants, this court, and others

about the withdrawal of their appraisal rights. They consistently represented that they no

3 longer wanted to pursue an appraisal proceeding and that they wanted to receive the

merger consideration.

TD Ameritrade attempted unsuccessfully to obtain the merger consideration for

the Mehtas. TD Ameritrade eventually told the Mehtas that they would have to deal

directly with Rock-Tenn Parent and Rock-Tenn Sub to obtain the merger consideration.

Even though no stockholder had filed an appraisal petition, the Rock-Tenn entities

took the positions that (i) the Mehtas only could receive the merger consideration if they

withdrew their demand for appraisal, (ii) the Mehtas only could withdraw their demand

for appraisal with Rock-Tenn Sub’s consent, and (iii) to receive Rock-Tenn Sub’s

consent, the Mehtas had to agree to a broader settlement, the details of which are not

relevant here. Because the Mehtas did not agree to any of the Rock-Tenn entities’

settlement proposals, Rock-Tenn Sub never provided the Mehtas with the merger

consideration.

D. This Litigation

The Mehtas filed this action on September 23, 2011. In substance, the Complaint

alleged claims for breach of fiduciary duty against the past and present directors of

Smurfit-Stone and the Rock-Tenn entities. The Complaint did not assert a claim for

appraisal.

After the Complaint was filed, the action languished for nearly a year. By letter

dated September 5, 2012, the court inquired as to whether the matter should be dismissed

for lack of prosecution pursuant to Rule 41(e). After receiving correspondence from the

Mehtas, the court informed them that the Complaint would be dismissed for lack of

4 prosecution if not served by October 31, 2012. The Mehtas filed an amended complaint

and served it on the defendants.

On November 11, 2012, the defendants filed a two-page motion to dismiss

pursuant to Rule 12(b)(6) and Rule 23.1. The motion to dismiss indicated that the

substance of the defendants’ arguments would be fleshed out in an opening brief to be

filed later. The action again became inert.

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