PREPA v. Vitol Inc., et al.

2016 DNH 057
CourtDistrict Court, D. New Hampshire
DecidedMarch 15, 2016
Docket09-cv-2242-SJM
StatusPublished

This text of 2016 DNH 057 (PREPA v. Vitol Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PREPA v. Vitol Inc., et al., 2016 DNH 057 (D.N.H. 2016).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

Autoridad de Energia Electrica de Puerto Rico, Plaintiff Case No. 09-cv-02242-SJM v. Opinion No. 2016 DNH 057

Vitol Inc., Vitol S.A., et al., Defendants

O R D E R

This suit was filed in 2009 by the Autoridad de Energia

Electrica de Puerto Rico (“PREPA”) in the Commonwealth Court of

First Instance, San Juan Part (“Commonwealth court”), against

Vitol Inc. and Vitol S.A. seeking, inter alia, a declaratory

judgment that certain oil supply contracts it had entered with

Vitol Inc. were rescinded by operation of local law. Defendants

removed the case to federal court, invoking this court’s

diversity subject matter jurisdiction, and asserted

counterclaims against PREPA. In 2012, PREPA filed a second

complaint in the Commonwealth’s court against Vitol Inc. and

Vitol S.A., d/b/a Vitol S.A., Inc., alleging similar causes of

action regarding four additional oil supply contracts.

Defendants removed that case to federal court as well, again

1 invoking the court’s diversity subject matter jurisdiction.

Subsequently, the two actions were consolidated.

The procedural history of the case is long and complicated.

Since removal of the action in December 2009, PREPA has

repeatedly moved for remand of the case to the Commonwealth’s

court based on forum selection clauses in the fuel supply

contracts. The history of the case appears to have been further

complicated by extensive motion practice between the parties, as

well as PREPA’s March 2015 motion to disqualify and/or for

recusal of the judge previously assigned to the case.

The case was reassigned in October of 2015, thereby mooting

PREPA’s motion to disqualify and/or recuse. Having reviewed the

existing docket, it appears that several motions are pending,

including a third motion to remand filed by PREPA, three fully

briefed motions for summary judgment, as well as two motions for

reconsideration of orders on motions in limine, and a motion for

reconsideration of the court’s September 30, 2014, order.

Because it appears from the record that the court has not

definitively resolved a critical issue, i.e. the applicability

2 of the forum selection clauses, 1 and because the forum selection

clauses determine whether the case should remain before this

court, that is an appropriate place to begin.

BACKGROUND

PREPA, a Puerto Rico public corporation, filed suit in

November 2009 against Vitol Inc., Vitol S.A., Carlos Benitez,

Inc. (“Benitez, Inc.”), and Fidelity & Deposit Company of

Maryland (“Fidelity”), 2 claiming that two oil supply contracts it

held with Vitol Inc. were “void” or were automatically rescinded

pursuant to Puerto Rico Act 458.

Puerto Rico Act 458 provides that public corporations, like

PREPA, may not award bids or contracts to a juridical person 3 who

1 To the extent defendants suggest that the issue was largely resolved in earlier rulings (except as to whether PREPA could prove its allegations that Vitol Inc. is the alter ego of Vitol S.A.) it does not appear so, and, in any event, the law of the case doctrine would not apply even if the issue had been finally resolved. See, e.g., Ellis v. U.S., 313 F.3d 636, 648 (1st Cir. 2002) (court may revisit earlier ruling to avoid “manifest injustice”). The relationship between the defendants is not critical to a determination of the applicability of the forum selection clauses to this case. 2 Benitez, Inc., and Fidelity subscribed Vitol Inc.’s performance bond required under the contracts. 3 “Juridical person” is defined by the statute to include “corporations, professional corporations, civil and mercantile partnerships, special partnerships, cooperatives and any entity defined as such in any applicable law, including those that 3 has pled guilty to, or been convicted of, any crime constituting

fraud, embezzlement or misappropriation of public funds. See 3

LRPA § 928. Act 458 further prohibits juridical persons who

have pled guilty to, or been convicted of, such crimes from

participating in the bidding process for a contract with a

public corporation, and from executing contracts with a public

corporation for 20 years after the date of conviction. See id.

The Act further provides that conviction “shall entail . . . the

automatic rescission of all contracts in effect on said date

between the person convicted or found guilty and any agency or

instrumentality of the Commonwealth government, [or] public

corporation.” 3 LRPA § 928c.

In November of 2007, Vitol S.A. pled guilty to grand

larceny fraud in a New York state court. PREPA makes several

assertions regarding that conviction, all of which arise from

PREPA’s contention that Vitol S.A. is an “alter ego” or

“partner” of Vitol Inc., as described in Act 458.

First, PREPA says that, pursuant to 3 LPRA § 928c, the

contracts in effect between Vitol Inc. and PREPA on the date of

Vitol S.A.’s conviction were automatically rescinded, and that

constitute, for these purposes, the alter ego of the juridical person or subsidiaries thereof.” 3 L.P.R.A. § 928a. 4 any contract executed after Vitol S.A.’s conviction is “null and

void ab initio” (document no. 160, p. 12) because Vitol Inc.

could no longer legally participate in the public

bidding/contract process.

PREPA also contends that, because the contracts at issue

required Vitol Inc. to represent that it was not prohibited from

contracting with Puerto Rico public authorities, and to submit a

sworn statement, attesting to whether it had pled guilty to, or

been convicted of such crimes, Vitol Inc. was contractually

required to inform PREPA of Vitol S.A.’s conviction. (Document

no. 113, p. 18-19.) Therefore, says PREPA, Vitol Inc.’s

omission violated both Act 458 and the contracts. PREPA’s 2009

complaint seeks declaratory relief, damages “caused by deceit in

the contracting process,” and damages for breach of contract.

(Document no. 1-3.)

PREPA’s subsequent complaint, filed in 2012 against Vitol

Inc. and Vitol S.A. d/b/a Vitol S.A., Inc., seeks similar relief

with regard to four additional oil supply contracts - three

between Vitol Inc. and PREPA, and one between PREPA and Vitol

5 S.A., Inc. 4 The contracts at issue in the 2009 and 2012 actions

contain choice of law and venue clauses.

First Motion to Remand

Following defendants’ removal of the case in December 2009,

PREPA timely filed a motion to remand, arguing: (1) complete

diversity between the parties was lacking because defendant

Benitez, Inc., was a citizen of the Commonwealth of Puerto Rico;

and (2) Vitol Inc. could not remove the case, or consent to

removal, because the forum selection clause in the contracts

between Vitol Inc. and PREPA was mandatory and enforceable.

Defendants countered that PREPA had improperly or fraudulently

included Benitez, Inc., as a non-diverse party to defeat

diversity jurisdiction. Defendants further argued that

enforcement of the forum selection clause would be unreasonable,

because Vitol S.A. was not a signatory party to the relevant

contracts.

The motion was referred to a magistrate judge, who found

that defendants had not established that PREPA included Benitez,

Inc., as a defendant to defeat diversity, and that the forum

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