Rankin v. Connecticut Municipal Electric Energy Cooperative

CourtDistrict Court, D. Connecticut
DecidedMarch 31, 2025
Docket3:23-cv-00805
StatusUnknown

This text of Rankin v. Connecticut Municipal Electric Energy Cooperative (Rankin v. Connecticut Municipal Electric Energy Cooperative) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rankin v. Connecticut Municipal Electric Energy Cooperative, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DREW RANKIN, Plaintiff,

v. No. 3:23-cv-00805 (VAB)

CONNECTICUT MUNICIPAL ELECTRIC ENERGY COOPERATIVE, Defendant.

RULING AND ORDER ON THE MOTION FOR PRELIMINARY INJUNCTION AND THE MOTION TO DISMISS

Mr. Drew Rankin (“Plaintiff”) has moved for a preliminary injunction against the Connecticut Municipal Electric Energy Cooperative (“CMEEC” or “Defendant”), requiring it to advance him legal fees in a criminal action resulting from his alleged conduct while serving as CMEEC’s Chief Executive Officer (“CEO”). CMEEC has opposed Mr. Rankin’s motion. Mr. Rankin has active litigation pending against CMEEC, in which he has plausibly alleged breach-of-contract and bad faith breach of the implied covenant of good faith and fair dealing in connection with its alleged refusal to advance him legal fees to defend against two criminal actions. Rankin v. Conn. Mun. Elec. Energy Coop., No. 23-cv-00805 (JAM), 2024 WL 1344790 (D. Conn. March 30, 2024). CMEEC has filed Counterclaims against Mr. Rankin, seeking declaratory relief from this Court, as well as damages for breach of contract, bad faith breach of the implied covenant of good faith and fair dealing, unjust enrichment, and fraudulent inducement. Mr. Rankin has filed a motion to dismiss all of CMEEC’s Counterclaims except its unjust enrichment claim, and CMEEC has opposed Mr. Rankin’s motion. For the following reasons, the motion for a preliminary injunction is DENIED and the motion to dismiss is DENIED. I. FACTUAL AND PROCEDURAL BACKGROUND A. Factual Allegations1

CMEEC is a non-profit, state-chartered cooperative of municipal electric utilities of various cities and towns in Connecticut, with its principal place of business in Norfolk, Connecticut. Countercl. and Answer ¶ 1, ECF No. 57 (April 15, 2024) (hereinafter “Countercl.”). Mr. Rankin is an individual who allegedly currently resides in Kentucky and is a former employee and CEO of CMEEC; he served in that role from January 1, 2011, to May 9, 2019. Id. ¶¶ 2, 4. CMEEC is governed by a board of directors comprised of representatives from each municipal electric utility, or their relevant municipality that is a member of CMEEC (“Board” or “the Board”). Id. ¶ 3. Article IV, § 6(a) of CMEEC’s bylaws allegedly require it to, under certain conditions, indemnify and hold harmless officers who face legal difficulties in connection with

their roles as officers “only if CMEEC is advised in writing by its counsel that in their opinion the person indemnified did not commit [] willful or wanton negligence or misconduct.” Opp’n MTD 7, ECF No. 78 (June 11, 2024). Article IV, § 6(b) of CMEEC’s bylaws allegedly require it to indemnify any employee for legal fees, “including the right to receive in advance reasonable legal fees actually incurred by the employee,” unless the employee is “finally adjudged” to have engaged in misconduct. Prelim. Injunct. at 2, ECF No. 55-1 (April 8, 2024) (hereinafter “P.I.”). During Mr. Rankin’s tenure as CEO, the United States Attorney’s Office for the District

1 The following is drawn from CMEEC’s Counterclaims, Mr. Rankin’s motion for a preliminary injunction, court filings in other relevant federal litigation, and the parties’ supplement briefing on intervening events that have impacted this litigation. of Connecticut initiated a grand jury investigation beginning in 2016 and continuing through October 2018, allegedly relating to, inter alia, accountings of payments and reimbursements to the Board, accountings of federal grants to CMEEC, accounting of the sources and funds used to pay Board members, and accountings related to CMEEC’s marginal fund. Countercl. ¶ 5.

In August 2018, while the grand jury investigation was ongoing, Mr. Rankin, who was still serving as CEO, allegedly entered into an Affirmation and Undertaking (“Affirmation”) concerning the payment of legal fees, expenses, and other costs that CMEEC advanced or reimbursed on his behalf. Id. ¶ 6. At that time, Mr. Rankin still allegedly owed a fiduciary duty to CMEEC. Id. The Affirmation allegedly stated: AFFIRMATION AND UNDERTAKING I, Drew Rankin, declare that I am currently an employee of the Connecticut Municipal Electric Energy Cooperative ("CMEEC"). In my actions undertaken as an employee of CMEEC, I acted in good faith and in a manner that I reasonably believed to be in, or not opposed to, the best interests of CMEEC, and I had a reasonable belief that my conduct was lawful. If it is ultimately determined in accordance with the by-laws of CMEEC, resolutions of the CMEEC Board of Directors and applicable state law that I am not entitled to indemnification, I will promptly repay CMEEC on request for the amounts of legal fees, expenses, and other costs that CMEEC has advanced or reimbursed on my behalf for legal fees and expenses. Id. On November 6, 2018, the United States Government allegedly filed two indictments against Mr. Rankin in two criminal proceedings, United States v. Rankin, et. al., 3:18-cr-00272 (“the ‘272 Action), and United States v. Rankin et. al., 3:18-cr-00273 (“the ‘273 Action”), concerning activities that, allegedly according to the indictments, involved Mr. Rankin in his capacity as a Member Representative or Officer of CMEEC. Id. ¶ 7. Mr. Rankin allegedly defended against the allegations in the ‘272 Action and was allegedly represented by counsel throughout the investigation and defense of the ‘272 Action. Id. ¶ 8. A jury convicted Mr. Rankin of one count of the ‘272 Action indictment in December 2021. Id. Based on Mr. Rankin’s representations and contingent on the Affirmation, CMEEC allegedly advanced and paid legal fees and expenses on his behalf during the investigation and for the

defense of the ‘272 Action after the return of indictments, and through the entry of final judgment in the ‘272 Action in the United States District Court for the District of Connecticut after Mr. Rankin’s conviction, sentencing, and entry of an order of restitution against Mr. Rankin. Id. ¶ 9; see also United States v. Rankin et al, 3:18-cr-00272, Order of Restitution re Drew Rankin, ECF No. 743 (Nov. 14, 2023); United States v. Rankin et al, 3:18-cr-00272, J. as to Drew Rankin, ECF No. 690 (May 24, 2023). Based on Mr. Rankin’s representations and contingent on the Affirmation, CMEEC also allegedly advanced and paid legal fees and expenses on Mr. Rankin’s behalf during the investigation and for the defense of the ‘273 Action after the return of the indictments, and continued to do so through the entry of final judgment in the ‘272 Action in the United States

District Court for the District of Connecticut after Mr. Rankin’s conviction, sentencing, and entry of an order of restitution against Mr. Rankin. Countercl. ¶ 10. The ‘273 Action had been stayed at the request of Mr. Rankin under Court orders entered on June 2, 2023, and January 19, 2024. Id.; see also United States v. Rankin et al, 3:18-cr-00273, Initial Pre-Tr. Scheduling Order, ECF No. 147 (June 2, 2023) (“The Court for the time being stays the setting of a trial date pending resolution of the defendants substantive motions and the pending appeals of the defendants in USA v. Rankin, 18cr272.”); United States v. Rankin et al, 3:18-cr-00273, Order, ECF No. 16 (Jan. 19, 2024) (“The Court . . . STAYS all briefing of substantive motions for both defendants in this case pending the Court of Appeals' determination of the appeal in United States v. Rankin et al., 18cr272.”). The Court continued the stay on November 6, 2024. United States v. Rankin et al, 3:18-cr-00273, Order Continuing Stay, ECF No. 175 (Nov. 6, 2024) (“[T]he Court STAYS this action pending the parties' submission of another joint status report within the next 30 days.”).

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Rankin v. Connecticut Municipal Electric Energy Cooperative, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rankin-v-connecticut-municipal-electric-energy-cooperative-ctd-2025.