Pee Dee Elec. Membership Corp. v. King

2018 NCBC 22
CourtNorth Carolina Business Court
DecidedMarch 15, 2018
Docket17-CVS-367
StatusPublished

This text of 2018 NCBC 22 (Pee Dee Elec. Membership Corp. v. King) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pee Dee Elec. Membership Corp. v. King, 2018 NCBC 22 (N.C. Super. Ct. 2018).

Opinion

Pee Dee Elec. Membership Corp. v. King, 2018 NCBC 22.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION ANSON COUNTY 17 CVS 367

PEE DEE ELECTRIC MEMBERSHIP CORPORATION,

Plaintiff,

v.

BRYAN J. KING; ACCUKING, INC., ORDER AND OPINION ON f/k/a KING AEROSPACE AND TECHNOLOGIES CORPORATION PLAINTIFF’S MOTION FOR f/k/a KING AEROTECH, INC.; and DEFAULT JUDGMENT TRITECH DIRECT CORPORATION,

Defendants.

1. THIS MATTER is before the Court on Plaintiff Pee Dee Electric

Membership Corporation’s (“Pee Dee” or “Plaintiff”) Motion for Default Judgment

(the “Motion”) in the above-captioned case.

2. The Court, having considered the Motion, Plaintiff’s brief in support of the

Motion, the testimony of Plaintiff’s witnesses at the February 28, 2018 hearing on the

Motion, and other appropriate matters of record, GRANTS in part and DENIES in

part Plaintiff’s Motion as to AccuKing and TriTech, ENTERS default judgment for

Plaintiff against AccuKing and TriTech, jointly and severally, and AWARDS

damages to Plaintiff as set forth below.1

Smith & Christensen, LLP, by Aaron M. Christensen, for Plaintiff Pee Dee Electric Membership Corporation.

1 Plaintiff’s Motion requests that Plaintiff’s actual damages be trebled and that Plaintiff be

awarded attorneys’ fees in an amount to be shown at the hearing. At the February 28, 2018 hearing, however, Plaintiff abandoned its request for attorneys’ fees, and the Court thus denies the Motion as to that request. Defendant Bryan J. King, Defendant AccuKing, Inc. f/k/a King Aerospace and Technologies Corporation f/k/a King Aerotech, Inc., and Defendant TriTech Direct Corporation did not appear.

Bledsoe, Judge.

I.

PROCEDURAL BACKGROUND

3. Plaintiff filed its Complaint on October 4, 2017 and served a copy of the

Summons and Complaint on Defendants Bryan J. King (“King”), AccuKing, Inc.

(“AccuKing”), and TriTech Direct Corporation (“TriTech”) (collectively, “Defendants”)

by United States Certified Mail, return receipt requested, on October 18, 2017.

Plaintiff made further attempts to communicate with Defendants in writing and by

telephone, but Defendants did not respond. Defendants did not file a responsive

pleading or any other documents with the Court.

4. On November 30, 2017, Plaintiff moved the Court for entry of default

against each Defendant. The Court entered default against each Defendant on

December 1, 2017, pursuant to Rule 55(a).

5. On December 18, 2017, Plaintiff moved for default judgment against all

Defendants, jointly and severally, pursuant to Rule 55 of the North Carolina Rules of

Civil Procedure. Plaintiff requested judgment without a hearing as to liability and

actual damages against any Defendant who failed to serve a written response in

opposition to Plaintiff’s Motion within thirty days of service of the Motion. See N.C.

R. Civ. P. 55(b)(2)(b)(1). 6. Plaintiff also requested a non-jury hearing on Plaintiff’s Motion to prove

that Plaintiff’s actual injuries were proximately caused by Defendants’ conduct for

purposes of Plaintiff’s claim for unfair and deceptive trade practices under N.C. Gen.

Stat. § 75-1.1. See Decker v. Homes, Inc./Constr. Mgmt. & Fin. Grp., 187 N.C. App.

658, 666, 654 S.E.2d 495, 501 (2007) (“The entry of default established the liability of

defendants under a theory of unfair and deceptive trade practices. However, in order

to recover damages arising from an unfair and deceptive trade practices claim, a

plaintiff must prove actual injury as a proximate result of the violation of N.C. Gen.

Stat. § 75-1.1.”).

7. Plaintiff served the Motion on December 18, 2017. Defendants did not

respond to the Motion.

8. On February 6, 2018, King filed for bankruptcy under Chapter 7 of the

United States Bankruptcy Code in the United States Bankruptcy Court for the

Eastern District of North Carolina. Neither TriTech nor AccuKing has appeared in

this case or filed for bankruptcy.

9. On February 28, 2018, the Court held an evidentiary hearing on the Motion,

at which Plaintiff was represented by counsel. Plaintiff offered live witness testimony

at the hearing. Defendants did not appear.

10. The Motion is now ripe for resolution. II.

EFFECT OF DEFENDANT KING’S BANKRUPTCY

11. “The initiation of . . . Chapter 7 . . . proceedings triggers an ‘automatic stay’”

in court proceedings under 11 U.S.C. § 362(a)(1). Tidewater Fin. Co. v. Williams, 498

F.3d 249, 252 (4th Cir. 2007); see Kreisler v. Goldberg, 478 F.3d 209, 213 (4th Cir.

2007). “Subsection (a)(1) is generally said to be available only to the debtor, not third

party defendants or co-defendants.” Kreisler, 478 F.3d at 213. Although “unusual

circumstances” present exceptions to this general rule, the Fourth Circuit has

expressly ruled that a debtor’s ownership of a non-bankrupt entity does not merit

extending the protections of the automatic stay to that non-bankrupt entity. Id. at

213–14 (“It is a fundamental precept of corporate law that each corporation is a

separate legal entity with its own debts and assets, even when such corporation is

wholly owned by another corporate entity. . . . Accordingly, had [the wholly-owned

entity] wished to receive the protections afforded by § 362(a)(1), it must have filed for

bankruptcy.”); see also Terry v. Yancey, 344 F.2d 789, 790 (4th Cir. 1965) (“[W]here

an individual creates a corporation as a means of carrying out his business purposes

he may not ignore the existence of the corporation in order to avoid its

disadvantages.”).

12. Further, the automatic stay will not apply to litigation against a non-

bankrupt entity owned by the debtor merely because that litigation may result in the

value of the debtor’s ownership interest decreasing. Kreisler, 478 F.3d at 214–15

(concluding that the automatic stay did not extend to an entity owned by the debtor when the proceedings against the owned entity “affected only the value of [the

debtor’s] interest,” not the nature and extent of that interest). The property of the

non-bankrupt entity is not the property of the debtor’s estate. Id. at 214 (noting that

an ownership interest in a legal entity does not give the owner a direct interest in the

assets of the entity).

13. For the reasons discussed herein, the Court concludes that AccuKing and

TriTech are liable to Plaintiff. Despite the fact that King may have an ownership

interest in AccuKing or TriTech, because AccuKing and TriTech are separate legal

entities from King, and because no facts indicate that AccuKing or TriTech are

entitled to absolute indemnity from King, entry of default judgment against AccuKing

and TriTech is not precluded by King’s bankruptcy. Id. at 213–15; see Nat’l Elec.

Benefit Fund v. 3W Elec. LLC, 2017 U.S. Dist. LEXIS 40992, at *7–8 (D. Md. Mar. 20,

2017) (“Courts, however, have not recognized membership in or ownership of an LLC

to constitute . . . an ‘unusual situation.’”); Ojiegbe v. Walter, 512 B.R. 513, 521–22

(Bankr. D. Md.

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