Plus Mgt. Servs., Inc. v. Liberty Healthcare Corp.

2024 Ohio 3127, 251 N.E.3d 288
CourtOhio Court of Appeals
DecidedAugust 16, 2024
Docket29858
StatusPublished
Cited by1 cases

This text of 2024 Ohio 3127 (Plus Mgt. Servs., Inc. v. Liberty Healthcare Corp.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Plus Mgt. Servs., Inc. v. Liberty Healthcare Corp., 2024 Ohio 3127, 251 N.E.3d 288 (Ohio Ct. App. 2024).

Opinion

[Cite as Plus Mgt. Servs., Inc. v. Liberty Healthcare Corp., 2024-Ohio-3127.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

PLUS MANAGEMENT SERVICES, : INC. : : C.A. No. 29858 Appellees/Cross-Appellants : : Trial Court Case No. 2017 CV 04263 v. : : (Civil Appeal from Common Pleas LIBERTY HEALTHCARE : Court) CORPORATION, et al. : : Appellant/Cross-Appellee

...........

OPINION

Rendered on August 16, 2024

ANNE MARIE SFERRA and CHRISTOPHER GORDON, Attorneys for Appellant/Cross- Appellee

TERRENCE G. STOLLY, CONNOR W. KINSEY, MATTHEW T. WATSON and CHRISTOPHER R. BUTLER, Attorneys for Appellees/Cross-Appellants

.............

TUCKER, J.

{¶ 1} Liberty Healthcare Corporation and its principal, Linda Black-Kurek, -2-

(collectively “Liberty”) appeal from the trial court’s entry of final judgment in favor of Plus

Management Services, Inc. (“Plus”) following a partial summary judgment and jury

verdicts in Plus’s favor on several claims. 1 Liberty also appeals from the trial court’s

disposition of post-trial motions and from the trial court’s awarding of prejudgment interest

to Plus. In a cross-appeal, Plus challenges the trial court’s entry of a directed verdict for

Liberty and Black-Kurek on punitive damages.

{¶ 2} With regard to Liberty’s appeal, we conclude that the trial court erred in

allowing Plus to obtain triple recovery of $280,000 by (1) entering summary judgment in

Plus’s favor for $280,000, (2) entering judgment on a jury verdict for conversion that

necessarily included the $280,000, and (3) entering judgment on a jury verdict for breach

of contract that included the same $280,000. The trial court also erred in awarding

prejudgment interest where Plus’s motion for such interest was untimely. As for Plus’s

cross-appeal, the trial court did not err in directing a verdict for Liberty and Black-Kurek

on punitive damages.

{¶ 3} The trial court’s entry of final judgment for Plus will be affirmed in part and

reversed in part. The trial court’s entry of a directed verdict for Liberty and Black-Kurek

on punitive damages issue will be affirmed.

I. Background

{¶ 4} The present appeal stems from Liberty’s operation and subsequent purchase

of a nursing home and residential-care facility owned by Plus. On January 11, 2017, the

1 We note that Liberty and Black-Kurek appealed separately. Black-Kurek styled her notice of appeal as a “cross appeal/multiple appeal” under App.R. 4(B), apparently because she filed it after Liberty’s appeal and after a cross-appeal by Plus. -3-

parties executed two agreements: an interim operating agreement and a purchase-and-

sale agreement. The interim operating agreement authorized Liberty to manage Plus’s

facilities prior to closing of the purchase-and-sale agreement, which occurred on April 21,

2017. The interim operating agreement provided for Liberty to supply working capital “in

an amount not to exceed $2,000,000 during the term of this Agreement.” This cash

infusion was referred to as the “Manager’s Contribution.” Under the agreement, any

unpaid balance was to be off-set against the purchase price at closing or otherwise repaid.

The Manager’s Contribution was intended to enable Plus’s facilities to continue operating

until closing of the purchase-and-sale agreement.

{¶ 5} Prior to closing, Liberty made total Manager’s Contributions of $2.54 million.

The outstanding principal balance never exceeded $2 million, however, because Liberty

periodically repaid itself from Plus’s operating accounts over which Liberty had control.

Shortly before closing, a dispute arose over whether Liberty had made unnecessary

capital expenditures to improve the condition of the facilities prior to closing rather than

simply paying required operating expenses. The parties also disagreed about whether

the interim operating agreement imposed a hard cap of $2 million on Liberty’s cash

infusion or whether it was a revolving line of credit, meaning that Liberty could contribute

an unlimited amount of money as long as the outstanding balance never exceeded $2

million. Ultimately, the parties agreed to a $280,000 reduction in the amount repayable

by Plus at closing on the Managers’ Contribution. They memorialized this agreement in a

second amendment to the purchase-and-sale agreement. It provided: “[T]he amount

payable as of the Closing Date for the Manager’s Contribution * * * including any accrued -4-

interest with respect to the Manager’s Contribution, shall be reduced by $280,000.”

{¶ 6} At closing, the balance owed on the Manager’s Contribution was $2,059,702.

This exceeded the $2 million limit by $59,702 but only at Plus’s explicit request to meet

payroll. On the closing statement, Liberty received a credit of $1,779,702 for its Manager’s

Contribution. This amount was calculated by taking the outstanding balance of

$2,059,702 and subtracting the negotiated $280,000 reduction.

{¶ 7} After the transaction closed, Liberty took the position that it was entitled to

recoup the $280,000 as a post-closing adjustment by collecting and retaining accounts

receivable that otherwise would have belonged to Plus. Liberty claimed the negotiated

language reducing “the amount payable as of the Closing Date for the Manager’s

Contribution” was not intended to forgive $280,000 of debt. Rather, Liberty asserted that

the amendment was intended to increase the cash to Plus at closing while saddling

Liberty with the burden of recouping those funds post-closing through Plus’s potentially

uncollectable accounts receivable.

{¶ 8} After taking ownership of the facilities, Liberty collected $382,490 in accounts

receivable that would have belonged to Plus under the purchase-and-sale agreement.

Liberty retained $280,000 of this amount as a post-closing adjustment to recoup its full

Manger’s Contribution. According to Liberty, the remainder of Plus’s accounts receivable

were offset by accounts payable for which Plus bore responsibility.

{¶ 9} Plus sued Liberty and its principal, Linda Black-Kurek, in September 2017.2

Plus later filed an amended complaint in August 2018. Among other things, it alleged

2 Plus’s complaint also named other defendants who later were dismissed and have no

relevance to this appeal. -5-

breach of the purchase-and-sale agreement, breach of the interim operating agreement,

conversion, and fraud. The complaint also sought a declaratory judgment that Liberty was

not entitled to recoup the $280,000 reduction in the Manager’s Contribution. In a January

3, 2020 ruling on competing summary-judgment motions, the trial court found a genuine

issue of material fact as to whether the Manager’s Contribution language in the interim

operating agreement created a revolving line of credit that could not exceed a $2 million

balance or whether it created hard cap of $2 million on Liberty’s cash infusion.

{¶ 10} With regard to the negotiated $280,000 reduction in Plus’s amount payable

as of the closing date for the Manager’s Contribution, the trial court found the amended

language in the purchase-and-sale agreement unambiguous. It determined that the

reduction was final and that Liberty had no right to recoup $280,000 by withholding Plus’s

accounts receivable after closing. The trial court characterized the reduction as “a

negotiated reduction of a liquidated sum, as opposed to a mere deferral of the amount

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2024 Ohio 3127, 251 N.E.3d 288, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plus-mgt-servs-inc-v-liberty-healthcare-corp-ohioctapp-2024.