Murphy Marine Services, Inc. v. Dole Fresh Fruit Company

CourtDistrict Court, D. Delaware
DecidedJanuary 13, 2022
Docket1:20-cv-00025
StatusUnknown

This text of Murphy Marine Services, Inc. v. Dole Fresh Fruit Company (Murphy Marine Services, Inc. v. Dole Fresh Fruit Company) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy Marine Services, Inc. v. Dole Fresh Fruit Company, (D. Del. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

MURPHY MARINE SERVICES, INC.,

Plaintiff,

v.

DOLE FRESH FRUIT CO., M/V DOLE No. 1:20-cv-25-SB HONDURAS, BARRY JUNG, DAVID LENNON, and CYNTHIA NUNES

Defendants.

Geoffrey G. Grivner, Andrew Hope, Craig Mills, BUCHANAN INGERSOLL & ROONEY P.C., Wilmington, Delaware; George R. Zacharkow, DEASEY, MAHONEY & VALEN- TINI, LTD, Philadelphia, Pennsylvania.

Counsel for Plaintiff.

Frank P. DeGiulio, Kevin G. O’Donovan, Michael B. McCauley, PALMER, BIEZUP & HENDERSON, Wilmington, Delaware.

Counsel for Defendants Dole Fresh Fruit and M/V Dole Honduras.

Michael B. McCauley, PALMER, BIEZUP & HENDERSON, Wilmington, Delaware.

Counsel for Defendants Barry Jung, David Lennon, and Cynthia Nunes.

MEMORANDUM OPINION January 13, 2022 BIBAS, Circuit Judge, sitting by designation. Parties to a contract cannot plan for everything. Sometimes, unexpected events disrupt their deal, making it too expensive to follow through. When that happens,

they need not stick to a commercially unworkable bargain. They may walk away with- out paying damages. Here, such an unforeseen event imposed new costs on the parties. So they could have abandoned their deal. Instead, Dole assured Murphy that it would bear the costs, inducing Murphy’s continued performance. Yet Dole later reneged. Those alle- gations are enough to state a claim for promissory estoppel. But the promises were

not knowingly false when made, so Murphy’s promissory-fraud claim fails. I. BACKGROUND Murphy Marine agreed to unload Dole Fresh Fruit Company’s ships at the Port of Wilmington. But that arrangement was disrupted when Delaware privatized the Port. The Port’s new operator, Gulftainer, imposed fees on all stevedores, including Murphy. Third Am. Compl., D.I. 84 ¶¶ 10−13. And those fees made unloading Dole’s ships much more expensive. Id. ¶ 27.

Murphy’s contract with Dole did not expressly say whether Dole would pay the fees. But faced with the prospect of losing money every time it unloaded a ship, Mur- phy told Dole “that [it] could not continue to work Dole vessels unless Dole was willing to reimburse [it].” Id. ¶ 30. In response, Dole executives assured Murphy that it would not “stiff” Murphy or “leave [Murphy] hanging.” Id. ¶ 35 (alteration in original). Reassured, Murphy paid the fees and kept unloading Dole’s ships. Id. ¶¶ 40, 46. Yet Dole never paid up.

So Murphy sued Dole, relying on a long list of contractual, quasicontractual, and tort theories. Last year, I dismissed many of those claims. Mem. Op., D.I. 79. But I allowed Murphy’s breach-of-contract and breach-of-good-faith claims to proceed. And I dismissed its promissory estoppel and fraud claims without prejudice, giving it an- other chance to plead those claims. Murphy seized that second chance and amended its complaint. It again alleges

promissory estoppel and fraud, plus it tacks on a new plea for punitive damages. Third Am. Compl. ¶¶ 121–44. Now, Dole moves to dismiss those claims. D.I. 85. To survive, Murphy’s complaint must contain enough facts to “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). II. MURPHY’S PROMISSORY ESTOPPEL CLAIM MAY PROCEED To state a claim for promissory estoppel, Murphy must plead that Dole promised

to pay the tariff, that Murphy reasonably relied on that promise, and that it suffered harm when Dole refused to pay. See Lord v. Souder, 748 A.2d 393, 399 (Del. 2000). Murphy’s last attempt to state this claim stumbled because it did not allege any harm. As I explained, “[w]hen [Murphy] was billed for the tariff, [it] had a choice. It could continue to unload Dole’s ships and pay the fee, or it could breach the contract and pay damages to Dole. Either way, Murphy would have to pay roughly the same amount of money.” D.I. 79, at 9. To get around that problem, Murphy now claims that it could have costlessly breached its contract with Dole because commercial impracticability excused it from performing. Third Am. Compl. ¶¶ 123−26. That argument creates a case within a

case. To evaluate it, I must consider a hypothetical dispute: What would have hap- pened had Murphy breached its contract with Dole and refused to unload Dole’s ships? Could it have raised commercial impracticability as a defense? At the motion-to-dismiss stage, Murphy plausibly alleges that it could have raised that defense. To claim commercial impracticability, Murphy would have had to show that Gulftainer’s imposition of fees was an unanticipated event that disrupted “a

basic assumption of the contract,” that the fees made Murphy’s “continued perfor- mance … commercially [im]practicable,” and that Murphy did not “agree to perform[ ] in spite of impracticability.” CRS Proppants LLC v. Preferred Resin Holding Co., 2016 WL 6094167, at *6, 8 (Del. Sup. Ct. Sept. 27, 2016); see also Restatement (Second) of Contracts § 261. Murphy checked those boxes here. To start, the fees were unanticipated. See Friedco of Wilmington, Del., Ltd. v. Farmers Bank of Del., 529 F. Supp. 822, 826 (D. Del. 1981). When the parties signed

the contract, the Port was state-run. So there was no need for their agreement to cover private fees. Indeed, Murphy says, had the tariff been imposed when the Port was state-run, it would have been a “tax,” which the contract allowed Murphy to pass along to Dole. D.I. 88, at 2. There were no equivalent private fees to allocate, so the parties likely did not think about it. The fees also undermined a basic assumption of the agreement, making it com- mercially impracticable for Murphy to perform. Under the contract, Dole paid Mur- phy a markup on its labor bill plus a management fee. Third Am. Compl. ¶ 28. That

payment structure was premised on Murphy’s making a profit over its costs. Yet the tariff meant that Murphy would lose money on the deal. Even Dole conceded that Murphy could not keep operating that way. Third Am. Compl. ¶¶ 30, 37; cf. Friedco, 529 F. Supp., at 830 (holding that a five-percent reduction in revenue is not enough to show commercial impracticability). Last, Murphy did not agree to perform despite the impracticability. True, Murphy

kept unloading Dole’s ships after the tariff was imposed. D.I. 85, at 7. But it did so only because Dole said it would cover the fees. Third Am. Compl. ¶ 35. It did not agree to continue under the original bargain. Dole protests that a commercial impracticability defense excuses only future per- formance; it does not authorize “retroactive relief.” D.I. 85, at 6. Thus, Dole says, Murphy cannot rely on commercial impracticability to get damages. True enough. But Murphy does not use the doctrine itself to claim relief. Instead, it uses the doctrine to

support its promissory-estoppel claim. Third Am. Compl. ¶¶ 123−26. Murphy con- tends that it could have walked away from the contract without paying damages be- cause the agreement was impracticable. Yet it did not do so because Dole promised to pay the tariff. Thus, it was harmed in reliance on that promise when Dole reneged. At this stage, that is enough for Murphy’s promissory estoppel claim to proceed. Of course, at summary judgment or trial, Dole may show that Murphy’s characterizations of events—including its commercial impracticability allegations— do not stand up to scrutiny. III. MURPHY’S FRAUD CLAIMS FAIL

Murphy’s second attempt to plead fraud does not pan out. It alleges that Dole and two of its executives—Barry Jung and David Lennon—misled it when they promised to pay for the tariff.

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