Shirley v. Limetree Bay Ventures, LLC

CourtDistrict Court, Virgin Islands
DecidedJuly 16, 2021
Docket1:21-cv-00259
StatusUnknown

This text of Shirley v. Limetree Bay Ventures, LLC (Shirley v. Limetree Bay Ventures, LLC) is published on Counsel Stack Legal Research, covering District Court, Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shirley v. Limetree Bay Ventures, LLC, (vid 2021).

Opinion

DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. CROIX

HELEN SHIRLEY, et al., ) ) Plaintiffs, ) ) v. ) ) Civil Action No. 2021-0259 LIMETREE BAY VENTURES, LLC, ) et al., ) ) Defendants. ) __________________________________________) ) BEECHER COTTON, et al., ) ) Plaintiffs, ) ) v. ) ) Civil Action No. 2021-0261 LIMETREE BAY VENTURES, LLC, ) LIMETREE BAY REFINING, LLC, ) LIMETREE BAY TERMINALS, LLC, ) ARCLIGHT CAPITAL PARTNERS, LLC, ) FREEPOINT COMMODITIES, LLC, EIG ) GLOBAL ENERGY PARTNERS, LLC, BP ) PRODUCTS NORTH AMERICA, and ) JOHN DOES, ) Defendants. ) __________________________________________)

Attorneys: John-Russell Bart Pate, Esq., St. Thomas, U.S.V.I. Korey A. Nelson, Esq., Charles Jacob Gower, Esq., New Orleans, LA Vincent A. Colianni, II, Esq., St. Croix, U.S.V.I. For Shirley Plaintiffs

Lee J. Rohn, Esq., St. Croix, U.S.V.I. For Cotton Plaintiffs Robert J. Kuczynski, Esq., Carl A. Beckstedt, III, Esq., St. Croix, U.S.V.I. For Defendants Limetree Bay Ventures, LLC, Limetree Bay Refining, LLC, and Limetree Bay Terminals, LLC

Charles Edward Lockwood, Esq., Gregg R. Kronenberger, Esq., St. Croix, U.S.V.I. Matthew Owen, Esq., Washington, DC For Defendant Arclight Capital Partners, LLC

Adam Nicholas Marinelli, Esq., St. Thomas, U.S.V.I. For Defendant EIG Global Energy Partners, LLC

Schuyler A. Smith, Esq., Jennifer Quildon Brooks, Esq., Miami, FL For Defendant BP Products North America

MEMORANDUM OPINION AND ORDER Lewis, District Judge THIS MATTER comes before the Court on “Plaintiffs’ Motion for a Protective Order Regarding Limetree’s Communications with Putative Class Members” (Dkt. No. 1-5 in 21-cv- 259) and “Plaintiffs’ Emergency Motion for Temporary Restraining Order and Preliminary Mandatory Injunction” (Dkt. No. 1-6 in 21-cv-261). Although the above-captioned civil actions are not consolidated, a combined oral argument was held on July 15, 2021 due to the overlap of certain issues contained in the aforementioned Motions. Based on the parties’ written submissions and oral arguments, this Memorandum Opinion and Order summarizes the issues addressed; embodies the Court’s rulings to date; discusses the current status of the proceedings; and memorializes the upcoming deadlines. 1. Bankruptcy Petition On July 12, 2021, Defendant Limetree Bay Refining, LLC (“Limetree Refining”) filed a Chapter 11 Petition for Bankruptcy with the United States Bankruptcy Court for the Southern District of Texas. (Dkt. No. 12-1 in 21-cv-259 and Dkt. No. 82-1 in 21-cv-261). A notice of the

bankruptcy was filed with this Court on July 14, 2021. (Dkt. Nos. 12 in 21-cv-259 and Dkt. No. 82 in 21-cv-261). Title 11 U.S.C. § 362(a)(1) provides that the filing of a bankruptcy petition results in an automatic stay of judicial proceedings against the debtor. Accordingly, the instant civil actions are stayed as they pertain to claims against Defendant Limetree Refining. See Maritime Elec. Co. v. United Jersey Bank, 959 F.2d 1194, 1206 (3d Cir. 1991) (“Once triggered by a debtor’s bankruptcy petition, the automatic stay suspends any non-bankruptcy court’s authority to continue judicial proceedings then pending against the debtor.”). The question remains, however, as to whether the automatic stay applies to Limetree Refining’s co-defendants in these matters. Defendants argue that because of the interwoven nature

and overlap of issues, facts, and law, the automatic stay also applies to the co-defendants. Defendant Arclight Capital Partners, LLC (“Arclight”) adds that the automatic stay should apply to the co-defendants from a sense of equity and fairness. In light of Third Circuit precedent, the Court is not convinced at this point that the automatic stay extends beyond Limetree Refining. See, e.g., Maritime Elec. Co., 959 F.2d at 1205 (“[T]he automatic stay is not available to non-bankrupt co-defendants of a debtor even if they are in a similar legal or factual nexus with the debtor.”); In re Exide Techs., 544 F.3d 196, 220 (3d Cir. 2008) (“[T]he intertwinement theory cannot be sustained.”). Before the Court renders a final ruling on the breadth of the automatic stay, the Court has granted Defendants’ request to brief the issue. Defendants shall have until July 27, 2021 within which to file their submissions. Plaintiffs shall have until August 3, 2021 within which to file their responses if there is essentially a single substantive submission from all Defendants, or until

August 9, 2021 if separate substantive submissions are filed. In turn, Defendants shall have until August 9, 2021 within which to file their replies if Plaintiffs file their responses on April 3, 2021, or until August 16, 2021 if Plaintiffs file their responses on August 9, 2021. While a final ruling on the issue of the applicability of the automatic stay to Defendant Limetree Refining’s co- defendants is pending, the Court will continue to address the matters before it. 2. Mandatory Injunctive Relief Plaintiffs in Cotton seek relief in the form of a mandatory injunction directing Defendants Limetree Bay Ventures, LLC (“Limetree Ventures”) and Limetree Bay Terminals, LLC (“Limetree Terminals”) to “properly clean up the oil spill, to include, but [not limited to,] cleaning Plaintiffs’ homes, cisterns, vehicles and grounds prompt[ly.]” (Dkt. No. 1-6 in 21-cv-261).1 In

order to be entitled to injunctive relief, the federal standard—which applies here, Instant Air Freight Co. v. C.F. Air Freight, Inc., 882 F.2d 797, 799 (3d Cir. 1989)—requires a showing by Plaintiffs of each of the following four factors: (1) a reasonable probability of success on the merits; (2) that they will suffer irreparable harm if the injunction is denied; (3) that granting

1 Plaintiffs clarified and confirmed at the hearing, or immediately prior thereto, that they do not seek injunctive or other relief against Defendants Arclight, EIG Global Energy Partners, LLC, and BP Products North America, LLC. Accordingly, the Court will deny as moot “Plaintiffs’ Emergency Motion for Temporary Restraining Order and Preliminary Mandatory Injunction” (Dkt. No. 1-6 in 21-cv-261) as to those Defendants. Defendant Freepoint Commodities, LLC (“Freepoint”) represented to the Court that it has not been served with a summons and complaint in the Cotton matter (Dkt. No. 77), and counsel for Cotton Plaintiffs could not advise the Court regarding the status of service on Defendant Freepoint. preliminary relief will not result in even greater harm to the nonmoving parties; and (4) that the public interest favors such relief, see N.J. Retail Merchs. Ass’n v. Sidamon-Eristoff, 669 F.3d 374, 385-86 (3d Cir. 2012). The first two factors—success on the merits and irreparable harm—are of particular importance as they are considered “threshold showings . . . .” Hope v. Warden York Cty.

Prison, 972 F.3d 310, 319 (3d Cir. 2020) (internal quotation marks and citation omitted). “A party seeking a mandatory preliminary injunction that will alter the status quo bears a particularly heavy burden in demonstrating its necessity.” Acierno v. New Castle Cty., 40 F.3d 645, 653 (3d Cir. 1994) (internal quotation marks and citation omitted). Based on the record before the Court, the Court finds that Cotton Plaintiffs have failed to establish irreparable harm because monetary relief would be available at the end of the proceedings.

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Related

Gulf Oil Co. v. Bernard
452 U.S. 89 (Supreme Court, 1981)
Frank E. Acierno v. New Castle County
40 F.3d 645 (Third Circuit, 1994)
In Re Exide Technologies
544 F.3d 196 (Third Circuit, 2008)
Coles v. Marsh
560 F.2d 186 (Third Circuit, 1977)
Instant Air Freight Co. v. C.F. Air Freight, Inc.
882 F.2d 797 (Third Circuit, 1989)
Maritime Electric Co. v. United Jersey Bank
959 F.2d 1194 (Third Circuit, 1991)

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Bluebook (online)
Shirley v. Limetree Bay Ventures, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shirley-v-limetree-bay-ventures-llc-vid-2021.