Social Amusement Co. v. Heroux

2 R.I. Dec. 121
CourtSuperior Court of Rhode Island
DecidedFebruary 24, 1926
DocketEq.No.7184
StatusPublished

This text of 2 R.I. Dec. 121 (Social Amusement Co. v. Heroux) is published on Counsel Stack Legal Research, covering Superior Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Social Amusement Co. v. Heroux, 2 R.I. Dec. 121 (R.I. Ct. App. 1926).

Opinion

BAKER, J-!

Heard on bill answer and proof.

The complainant brings this bill against the respondent, asking. that the latter be compelled to surrender and deliver cefitain shares of stock of the complainant corporation for cancellation and that the issuing of said stock may be declared to be illegal.

The chief facts involved in the case are not seriously in dispute.

Early in 1919 the complainant corporation was organized for the purpose of erecting and operating a theatre located in what is known as the Social District in the ■ city of Woonsocket. The respondent was not one of the original incorporators, although he was vitally interested in the enterprise. He had been for some years president of the Chamber of Commerce of the Social District in said city and had advocated the erection of a theatre there, and he became one of the orig-inatorte and promoters of the complainant corporation.

The records show that at a meeting of the Board of Directors Feb[122]*122ruary 3, 1919, he was elected secretary and general manager of the corporation and authority was given to him to sell the shares of the corporation at a commission. He did sell a large number of shares. He soon became a stockholder to a considerable amount in the new company but lie was not a member of the original board of director's. Land was acquired in the year 1919 and the erection of a theatre was begun and continued into the year 1920. Several times the respondent offered to resign as general manager by reason of some little friction with other officers or members of the board, but his resignation was not accepted and matters were amicably adjusted.

At a meeting held on January 13, 1920, it was voted by the Board of Directors that a bonus of $2000' be paid to each director and also to the secretary manager, the respondent. While in form this vote was for a cash 'bonus, in actual effect it was for ■the issuing of $2000 worth of shares in the corporation and the bonus so voted was issued in the form of shares.

This vote was passed immediately prior to the annual stockholders’ meeting of the corporation held early in February 1920, but no action was taken at that meeting ratifying the action of the Board of Directors, and as far as would appear the general stockholders knew nothing of the issuing of said shares.

The records show that the respondent was paid a salary for performance of his duties as secretary but there is no vote authorizing* the pay-pienit of any salary to him by reason of his being genaral manager. A receipted bill for the respondent’s services as secretary is one of the exhibits in the case. The records of the Board of Directors then show that on April 6, 1920, a further payment of $2000 was to be given each director, payable in stock, which was issued. At this, time the .respondent was a member of the Board of Directors, having been- elected at. the annual stockholders’ meeting early in February.

I’t appears that when the books of the corporation were audited in 1920, the question was raised as to' thé legality of these issues of bonus stock, and at a meeting of the Board of Directors held August 18, 1920, it was voted “that all the shares andi bonus voted for the directors be annulled and the shares taken returned and cancelled.”' All the shares held by the directors and officers other than the respondent were returned to the corporation. The respondent returned for cancellation the shares issued to him under the vote of April 6', 1920, at which time he was a director, but declined to return [the 100 shares of a par value of $20' each issued to him under the vote of January 13, 1920, and these are the shares involved in the present litigation. .

In determining the question before* the court, it becomes necessary to consider somewhat the law relating to» the issuing of corporate shares. It would seem that if directors have the power in any given instance to pay-compensation to officers by way of salary for services rendered, then such payment can be made by issuing stock of the company not previously issued in lieu of money, if the officers are willing to take their' compensation in that form.

Thompson on Corporations 2d ed.r Vol. 2, Sec. 1751.

It seems to be equally well settled,, however, that it is a broad principle of the law that the assets of a corporation are a trust fund in the hands of the directors and officers which they can not apply or divert to themselves.

Ellis vs. Ward, 137 Ill. 509.

Further, it would seem that in the ordinary case where an officer of a [123]*123corporation is also a stockholder, in order -ior him to recover compensation from the corporation for the usual services rendered thereto in performing his duties as such officer, there must be an express agreement or understanding and if none is expressed, none will be implied.

Fletcher Cyc. Corp., Vol. 4, Sec. 2736.

Loe vs. Ring, 123 Wis. 370.

Metropolitan Rubber co. vs. Place, 147 Fed. 90.

Citizens’ Nat’l Bank vs. Elliott, 55 Ia. 104.

Blue vs. Capital Nat’l Bank, 145 Ind. 518.

Woods’ Sons Co. vs. Schaefer, 173 Mass. 443.

It would also seem to be well recognized that directors or managing officers of a corporation can not legally vote to themselves or other officers ' compensation for past services where there is no agreement that such officers should be paid.

Fletcher Cyc. Corp., Vol. 4, Sec. 2762.

Thompson on Corporations, 2d ed., Voh 2, Sec. 1765.

Apparently, however if an officer of a corporation performs services for the corporation which are extraor-rinary and entirely outside the usual duties of that officer, then he can "eeover at law on a quantum meruit from the corporation for the reason able value of such services.

Flynn vs. Columbus Club, 21 R. I. 534.

It will be presumed however, that services rendered for a corporation by an officer will be done by him in the course of his employment as such officer unless from the nature of the services, or from the evidence, it appears otherwise.

Olney, Receiver, vs. Chadsey, 7 R. I. 224.

In the ease at bar the complainant contends that the shares which it is seeking to recover from the respondent were issued illegally and for past services for which no compensation, on the facts, could properly be tv-»-sumed or implied, and further, that the respondent was actually a promoter of the enterprise in question and that also, on the evidence, he specifically agreed and promised to return the shares in question.

The respondent, on the other1 hand, denies the contentions of the complainant and argues thait he is entitled to retain the shares in question as part compensation, for services rendered the corporation, such services being unusual and extraordinary and outside of those called for from a general manager of such a corporation as the one in question.

An examination of the evidence in the case in connection with the respondent’s position as manager leads the Court to the conclusion that he was not a mere employee of the complainant corporation and that his duties as manager were not just ministerial but that the testimony shows clearly that the respondent as manager was one of the regular directing officers of the corporation, having an interest therein far exceeding that of one merely hired to fill such a position.

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Related

Henry Wood's Sons Co. v. Schaefer
53 N.E. 881 (Massachusetts Supreme Judicial Court, 1899)
Ellis v. Ward
25 N.E. 530 (Illinois Supreme Court, 1890)
Blue v. Capital National Bank
43 N.E. 655 (Indiana Supreme Court, 1896)
Citizens' National Bank v. Elliott
7 N.W. 470 (Supreme Court of Iowa, 1880)
Lowe v. Ring
101 N.W. 698 (Wisconsin Supreme Court, 1904)
Metropolitan Rubber Co. v. Place
147 F. 90 (Second Circuit, 1906)

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Bluebook (online)
2 R.I. Dec. 121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/social-amusement-co-v-heroux-risuperct-1926.