Olson v. Gleichman

CourtSuperior Court of Maine
DecidedJune 5, 2020
DocketCUMbcd-cv-19-21
StatusUnpublished

This text of Olson v. Gleichman (Olson v. Gleichman) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Olson v. Gleichman, (Me. Super. Ct. 2020).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, ss. DOCKET NO. BCD-CV-2019-00021

RICHARD P. OLSON, Trustee of the Promenade Trust, ) ) Plaintiff ) ORDER GRANTING ) PLAINTIFF'S MOTION v. ) TO STRIKE JURY DEMAND ) PAMELA GLEICHMAN, et al., ) ) Defendants )

Before the Court is Plaintiffs Motion to Strike Jury Demand on the grounds that the

claims in question primarily seek equitable remedies. For the following reasons, the Court grants

Plaintiffs Motion.

Background

The claims before the Comi include Plaintiffs Amended Complaint and Defendant

Hancock's Counterclaim against Plaintiff and Cross-Claim against Defendant General Holdings.

Plaintiffs Amended Complaint alleges fraudulent transfer as to Defendants Gleichman and

Hancock. 1 Plaintiff Richard Olson alleges that he is trustee of the Promenade Trust, which holds

several judgments against Defendant Gleichman. He further asse1is that while owing over 11

million dollars to the Promenade Trust and while she was insolvent within the meaning of 14

M.R.S. § 3573, Defendant Gleichman made transfers of several partnership interests to

Defendant Ellen Hancock in violation of 14 M.R.S. §§ 3575 and 3576, Maine's fraudulent

1 Plaintiffs claim against Defendant General Holdings was resolved in the Coutt's Order on Summary Judgment issued 7/7/2021.

1 transfer statutes. Plaintiff requests relief including voiding the allegedly fraudulent transfers, a

provisional remedy against the asset transferred or other prope1iy, enjoining fmiher dispositions

by Defendants, and damages not to exceed double the value of property transferred.

Defendant Ellen Hancock's counts, as to both Plaintiff and Defendant General Holdings,

include unjust emichment, conversion, breach of fiduciary duties and aiding and abetting, breach

of contract, and a request for an accounting. According to Hancock, General Holdings, under

agreement as general partner of several housing projects, has been required to pay certain assets

to two trusts for which she serves as trustee and to the Promenade Trust, for which Plaintiff

serves as trustee. Hancock alleges that General Holdings has improperly paid sums to the

Promenade Trust and that the Promenade Trust retained those assets which were rightfully owed

to her trusts. As relief, she requests damages, an accounting, costs and attorney fees, and

dismissal of the Amended Complaint.

Legal Standard

The Maine Constitution grants parties the right to trial by jury "[i]n all civil suits, and in

all controversies concerning property ... except in cases where it has heretofore been otherwise

practiced .... " Me. Const. aii. I, § 20. The Law Court has construed that provision to provide

the right "unless it is affirmatively shown that a jury trial was unavailable in such a case in

1820." North School Congregate Housing v. Merrithew, 558 A.2d 1189, 1190 (Me. 1989). In

1820, legal claims in Maine were entitled to jmy trials, while equitable claims were not. See

DesMarais v. Desjardins, 664 A.2d 840, 844 (Me. 1994). To determine whether a claim is legal

or equitable, the Law Comt has instructed "appraisal of the basic nature of the issue presented,

including the relief sought." Id. at 1016. "Where a plaintiff seeks damages as full compensation

2 for an injury, the claim is legal and the plaintiff is entitled to a jury trial. On the other hand,

when the primary recovery pursued is equitable, the inclusion of a request for money damages

does not convert the proceeding into an action at law." Id. at 844 (citation omitted).

Analysis

Plaintiff's Complaint

Plaintiff argues that no jury right is available because his claims primarily seek equitable

relief, with the "thrust of Plaintiffs action [being] to 'avoid' the purported transfer either

because it was a juridical nullity as never legally effectuated or because, if a transfer occurred at

all, it violated Maine's fraudulent transfer statute." Plaintiffs Motion to Strike at 1.

Defendants reply that Plaintiff has not carried his burden to show that there is no right to

jmy trial, that historically fraudulent transfer claims were not exclusively heard in equity, that

Plaintiffs claims seek legal relief and have factual elements requiring a jury's factfinding, and

that the issue of what relief is primarily sought is irrelevant.

To succeed on his Motion, Plaintiff must prove that his fraudulent transfer action would

have been tried to a comi of equity in 1820. The Court finds that Plaintiff has carried this

burden. Defendant is incorrect that the primaty remedy sought is irrelevant; Plaintiff may meet

his burden by showing the primary recove1y he requests is equitable. See DesMarais, 664 A.2d

at 844. The right to a jury trial is not so broad that it applies to ancillary legal claims in suits at

equity. Id.

Both parties cite to a Superior Court opinion, WCP Me. Loan Holdings, LLC v. Norberg,

2019 Me. Super. LEXIS 4 (Jan. 16, 2019), addressing a similar issue. This Comi finds that case

persuasive. In that case, the Superior Court (Hat1cock County, R. Murray,.!) held that a

3 fraudulent transfer claim seeking equitable relief and damages did not carry a jmy trial right

under the Maine Constitution. Defendants in the case at hand make a similar argument to that

made in Norberg. They point to cases involving fraudulent transfer claims heard by juries in

Maine in an attempt to show that juries have historically been available for fraudulent transfer

cases. As addressed in Norberg, the fraudulent transfer claims in those cases were ancillary to

claims at law, which did afford the jury right. When fraudulent transfer claims seeking equitable

relief constituted the primary concern in a case, the case was heard in equity without ajury. 2

In Norberg, the Superior Court found that the primary issues were whether the transfer

should be voided, whether Defendants should be enjoined from fmther transfers, and whether a

receiver should be appointed to oversee the property, 2019 Me. Super. LEXIS 4, at * 12. It held

these were equitable issues. Similarly, the issues in Plaintiffs Amended Complaint are whether

the transfers should be voided, whether a provisional remedy should be granted against the

transferred property, and whether the Defendants should be enjoined from further transfers. The

Comt finds these issues to be equitable.

2 Compare Ricker v. Ham, 14 Mass. 137 (1817) Uury tt·ial where primary claim was trespass at law), and Blake v. Howard, 11 Me. 202 (1834) Uury trial where primaiy claim was trespass at law), and Whitehouse v. Bolster, 95 Me. 458, 50 A. 240 (190 I) Uury trial where primmy claim was for writ of entt·y at law), and Blanchard v. Baker, 8 Me. 253 (1832) Umy trial where prim my claim was trespass at law), and Eastman v. Fletcher, 45 Me. 302 (1858) Uury trial where primaty claim was for writ of entty at law), with Stover v. Poole, 67 Me. 217 ( 1877) (action in equity to remove cloud on title due to a fraudulent deed), and Dana v. Haskell, 41 Me. 25 (1856) (fraudulent transfer claim seeking return of property heard in equity), and Whitmore v. Woodward, 28 Me. 392 (1848) (fraudulent transfer claim seeking compelled conveyance of property heard in equity), and Traip v. Gould, 15 Me.

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Olson v. Gleichman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/olson-v-gleichman-mesuperct-2020.