Scrapit v. Del Angel Recycling Corp. CA2/1

CourtCalifornia Court of Appeal
DecidedJanuary 25, 2023
DocketB313691
StatusUnpublished

This text of Scrapit v. Del Angel Recycling Corp. CA2/1 (Scrapit v. Del Angel Recycling Corp. CA2/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scrapit v. Del Angel Recycling Corp. CA2/1, (Cal. Ct. App. 2023).

Opinion

Filed 1/25/23 Scrapit v. Del Angel Recycling Corp. CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION ONE

SCRAPIT, LLC et al., B313691

Plaintiffs, Cross-defendants (Los Angeles County and Respondents, Super. Ct. No. LC102732) v.

DEL ANGEL RECYCLING CORPORATION et al.,

Defendants, Cross- complainants and Appellants.

APPEAL from a judgment of the Superior Court of Los Angeles County, Huey P. Cotton, Judge. Conditionally affirmed as modified. Crawford Law Group, Roza Crawford and Daniel A. Crawford for Defendants, Cross-complainants and Appellants. Marchetti Law and Frank E. Marchetti for Plaintiffs, Cross-defendants and Respondents. _________________________ INTRODUCTION Following a bench trial and a court-ordered forensic accounting, respondents Scrapit, LLC (Scrapit), its owner Antoun Chiha, and his wife Sandra Chiha were awarded $175,454.67 in damages payable by appellants Ricardo Del Angel Bandala (Bandala), Elfego Del Angel (Del Angel), Luis Suarez and Makina, Inc. (Makina). Those damages arose from the dissolution of the parties’ metal recycling business partnership. Appellants do not challenge any of the trial court’s liability findings, including that they breached the partnership agreement and their fiduciary duties to respondents, and fraudulently induced respondents to invest in the partnership. Nor do appellants challenge the trial court’s order dissolving the partnership as of March 13, 2015, the court’s conclusion that Scrapit held a one-third interest in the partnership, or the findings of the court-appointed forensic accountant. Appellants contend only that the trial court erred in measuring damages. Based on the forensic accounting report, the trial court awarded respondents Scrapit’s one-third share of the adjusted net profit of the partnership through the dissolution date, plus a one-third share of the business’s inventory as of that date. We agree with appellants that this was error, because among other things (1) the adjusted net profits calculation incorporated the value of the inventory, meaning the damages award double-counted the value of the inventory, and (2) the damages calculation included a partnership asset without accounting for offsetting partnership liabilities. The parties dispute what the appropriate alternative or corrected damages number should be. For the reasons explained below, we find respondents’ arguments concerning the calculation

2 of damages unpersuasive. Instead, we agree with appellants that the proper measure of damages is Scrapit’s one-third interest in the partnership’s net assets (total assets minus total liabilities as of the dissolution date), a formula that comports with the applicable Corporations Code1 provisions. Appellants, however, incorrectly contend that the partnership’s net assets equal the partnership’s adjusted net profit. Those are two very different things. Assets minus liabilities is the partnership’s net assets; adjusted net profit is the net income generated by the partnership during a specified period. The undisputed forensic accountant report calculated total partnership assets of $731,358.62 and total partnership liabilities of $253,213.30 as of the dissolution date. Subtracting the liabilities from the assets gives a net asset figure of $478,145.32 (a figure the forensic accountant’s report explicitly includes as the partnership’s total equity). Scrapit’s one-third interest of this amount is $159,381.77. Accordingly, we conditionally affirm the judgment as modified to award $159,381.77 in damages subject to respondents’ consent to this modification pursuant to California Rules of Court, rule 8.264(d). If respondents do not timely file a consent in the Court of Appeal to this reduction, the damages award is to be reversed and the matter remanded for a new trial limited to determining the amount of damages, as liability has been established. (See Cal. Rules of Court, rule 8.264(d).)

1 Unspecified statutory references are to the Corporations Code.

3 FACTUAL AND PROCEDURAL BACKGROUND A. The Parties Form a Partnership2 In September 2012, Del Angel and Bandala started operating a metal recycling business through a partnership with Makina (which was owned by Suarez) and Eduardo Barajas Hernandez. Bandala and Del Angel jointly held one partnership unit. Shortly thereafter, Sandra and Antoun Chiha began discussing with Bandala and Del Angel the possibility of joining the partnership. Bandala informed Sandra Chiha that the business either had, or was soon going to have, all of the necessary permits and licenses. Bandala and Del Angel told the Chihas that each of the three partners had invested $50,000 into the business. They also told the Chihas that all of the business’s equipment was owned free and clear and that the only debt of the partnership was a $13,000 loan which they wanted the Chihas to pay off as part of their investment. The Chihas joined the partnership through Scrapit, a company owned by Antoun Chiha. The Chihas began working at the business in early November and a partnership agreement was signed on December 12, 2012. Under the partnership agreement, there were four partners each holding a 25 percent interest in the partnership: Bandala,3 Makina, Hernandez and

2The factual summary is taken primarily from the statement of decision issued by the court on May 4, 2021. Appellants do not dispute any of the court’s factual findings. 3Bandala held his interest in the partnership for himself and Del Angel.

4 Scrapit. Scrapit invested $50,000 in the business, as required by the partnership agreement. Sandra Chiha, who had years of experience in the recycling industry, initially managed the business’s operations. She received $500 per week for her work, Bandala received $500 per week, and Antoun Chiha and Del Angel each received $300 per week. Suarez and Hernandez did not work at the business and did not receive any regular payments. B. Disputes Arise Among the Parties and the Chihas Stop Participating in Business Operations Soon after the Chihas started working at the business they learned that appellants had not applied for many required licenses and permits, including a scrap metal dealer permit. They also found out the business had debts that appellants had not disclosed. Because it did not have a scrap metal dealer permit, the business closed in late November 2012, and did not reopen until mid-January 2013. The Chihas became suspicious that the other partners had not invested $50,000 as had been represented, so they requested each partner submit proof of their investment. Suarez presented evidence that he had invested $50,000. Bandala and Del Angel were not able to prove their full investment, but the partners nonetheless voted to approve a full partnership share for them because Del Angel had put labor into the business; the Chihas agreed to this in part because they did not believe the business could operate without Bandala and Del Angel. Hernandez was unable to show proof that he had invested $50,000 and the partners never voted to approve his investment. As a result, Scrapit’s partnership share (as well as that of the other approved partners) effectively increased from one-quarter to one-third.

5 When the business resumed operations in mid-January 2013, Sandra Chiha again started receiving $500 per week and Antoun Chiha again started receiving $300 per week. According to Del Angel, at this time both he and Bandala began receiving $800 per week.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sargon Enterprises, Inc. v. University of Southern California
288 P.3d 1237 (California Supreme Court, 2012)
Hurtado v. Superior Court
522 P.2d 666 (California Supreme Court, 1974)
GHK Associates v. Mayer Group, Inc.
224 Cal. App. 3d 856 (California Court of Appeal, 1990)
New West Charter Middle School v. Los Angeles Unified School District
187 Cal. App. 4th 831 (California Court of Appeal, 2010)
JMR Construction Corp. v. Environmental Assessment & Remediation Management, Inc.
243 Cal. App. 4th 571 (California Court of Appeal, 2015)
Greenwich S.F., LLC v. Wong
190 Cal. App. 4th 739 (California Court of Appeal, 2010)
Scheenstra v. California Dairies, Inc.
213 Cal. App. 4th 370 (California Court of Appeal, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Scrapit v. Del Angel Recycling Corp. CA2/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scrapit-v-del-angel-recycling-corp-ca21-calctapp-2023.