Racing Investment Fund 2000, LLC v. Clay Ward Agency, Inc.

CourtKentucky Supreme Court
DecidedAugust 25, 2010
Docket2009 SC 000007
StatusUnknown

This text of Racing Investment Fund 2000, LLC v. Clay Ward Agency, Inc. (Racing Investment Fund 2000, LLC v. Clay Ward Agency, Inc.) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Racing Investment Fund 2000, LLC v. Clay Ward Agency, Inc., (Ky. 2010).

Opinion

RENDERED : AUGUST 26, 2010 TO BE PUBLISHED

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RACING INVESTMENT FUND 2000, LLC APPELLANT

ON REVIEW FROM COURT OF APPEALS V. CASE NO . 2007-CA-002282-MR FAYETTE CIRCUIT COURT NO . 02-CI-00769

CLAY WARD AGENCY, INC . APPELLEE

OPINION OF THE COURT BY JUSTICE ABRAMSON

REVERSING AND REMANDING

Racing Investment Fund 2000, LLC is a limited liability company created

in August 2000, to purchase, train and race thoroughbred horses. In May,

2004, Racing Investment entered into an agreed judgment with its former

equine insurance firm, Clay Ward Agency, Inc., for past-due insurance

premiums. Shortly thereafter, Racing Investment partially paid the judgment

by tendering all of the remaining assets of the then-defunct limited liability

company. When Racing Investment failed to pay the remainder of the amount

owed, Clay Ward succeeded in having Racing Investment held in contempt of

court for its failure to pay the entire judgment amount . Specifically, the trial

court ruled that a provision in Racing Investment's Operating Agreement which

allowed the limited liability company's Manager to call for additional capital contributions, as needed, from all members on a pro rata basis for "operating,

administrative or other business expenses" provided a means of satisfying the

Clay Ward judgment . The trial court ordered that Racing Investment "act

accordingly to satisfy the Judgment within a reasonable period of time" or face

other sanctions . After the Court of Appeals affirmed, this Court granted

discretionary review to consider whether the capital call provision can be

invoked by a court to obtain funds from the limited liability company's

members in order to satisfy a judgment against the limited liability company.

Having concluded that KRS 275 .150 provides for immunity from personal

liability for a limited liability company's debts unless a member agrees

otherwise and, further, that members of Racing Investment did not, by signing

an operating agreement allowing for periodic capital calls from the Manager,

subject themselves to personal liability, we reverse .

RELEVANT FACTS

As noted, Racing Investment was formed as a limited liability company in

August 2000 to engage in thoroughbred horse racing . The Operating

Agreement provided for fifty units to be sold for an initial capital contribution of

$100,000 per unit and allowed the Manager on an as-needed basis, subject to

some limitations, to call for additional capital from the members in order to pay

operating, administrative or other business expenses . The Manager of Racing

Investment was Gaines-Gentry Thoroughbreds, LLC, which, as it name

suggests, is a limited liability company in its own right. Games-Gentry was the manager of a number of thoroughbred racing

limited liability companies which, for several years, purchased equine

insurance coverage through Clay Ward . Games-Gentry eventually brought suit

against Clay Ward for breach of contract, fraud and negligence claims arising

out of the alleged mishandling of the insurance of a foal and a stallion, neither

of which was owned by Racing Investment . During the course of Gainer-

Gentry's dispute with Clay Ward, Racing Investment did not pay certain

insurance premiums it owed for coverage of its horses. In the course of the

Gainer-Gentry litigation, Clay Ward eventually moved for summary judgment

on its counterclaims against Racing Investment for the unpaid insurance

premiums, a motion which Racing Investment did not oppose . After the matter

of the prejudgment interest was resolved between the parties, Clay Ward and

Racing Investment entered into an agreed judgment on May 27, 2004 for $69,

858 .96, of which $12,719 .28 was paid shortly thereafter .

As referenced supra, Clay Ward succeeded in its efforts to have Racing

Investment held in contempt for failure to pay the outstanding balance of

$57,139 .68 as well as any post judgment interest . The trial court and the

Court of Appeals concluded that a provision in Racing Investment's Operating

Agreement which allows the Manager to make additional capital calls provided

a means for obtaining funds to satisfy the Clay Ward judgment, i.e., a capital

call should issue to each member of the LLC for his, her or its pro rata share of

the balance owed on the judgment . The trial court also concluded that Racing

Investment was in contempt of court for failing to have called for additional capital from its members, a position which the Court of Appeals affirmed as

properly within the trial court's discretion . Having granted discretionary

review, we turn first to Kentucky Revised Statutes (KRS) Chapter 275 and

general principles governing limited liability companies, and then the specific

provisions of the Operating Agreement.

ANALYSIS In 1994, Kentucky joined a growing national trend by recognizing limited

liability companies (LLCs) through the adoption of the "Kentucky Limited

Liability Company Act" codified at KRS Chapter 275 . As early commentators

noted, the hallmark of this new form of business entity is its combination of

the income tax advantages of a partnership with the business advantages of a

corporation . Thomas Rutledge and Lady Booth, The Limited Liability Company

Act: Understanding Kentucky's New Organizational Option, 83 Ky. L.J . 1 (1994-

95) . The "centerpiece" of a limited liability company is its "provision for limited

liability of its members and managers in regard to the debts and obligations of

the LLC . . . ... Id. at 6 . See also Charles Fassler, Kentucky Limited Liability

Company § 1 .7 (2009) ("The most important feature of an LLC is its limited

liability protection . . . . It is this limited liability that makes an LLC such a

valuable entity .") One indicia of the strength of that limited liability protection

is the Internal Revenue Service's recognition that federal employment tax liabilities incurred by an LLC cannot be collected from the LLC's members .

citing Rev . Rul. 2004-41, 2004-1 C.B . 845 . 1

Kentucky codified the limited liability feature of a limited liability

company at KRS 275 .150 - "Immunity from personal liability":

Except as provided in subsection. (2) of this section or as otherwise specifically set forth in other sections in this chapter, no member, manager, employee, or agent of a limited liability company, including a professional limited liability company, shall be personally liable by reason of being a member, manager, employee, or agent of the limited liability company, under a judgment, decree, or order of a court, agency, or tribunal of any type, or in any other manner, in this or any other state, or on any other basis, for a debt, obligation, or liability of the limited liability company, whether arising in contract, tort, or otherwise . The status of a person as a member, manager, employee, or agent of a limited liability company, including a professional limited liability company, shall not subject the person to personal liability for the acts or omissions, including any negligence, wrongful act, or actionable misconduct, of any other member, manager, agent, or employee of the limited liability company .

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