Temm v. LPL Financial LLC

CourtSuperior Court of Maine
DecidedApril 29, 2016
DocketCUMcv-16-0014
StatusUnpublished

This text of Temm v. LPL Financial LLC (Temm v. LPL Financial LLC) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Temm v. LPL Financial LLC, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERIOR COURT

Cumberland, ss.

WILLIAM TEMM and DALE TEMM

Plaintiffs

V. Docket No. PORSC-CV-16­ 0014

LPL FINANCIAL LLC, TRSS WEAL TH MANAGEMENT LLC, MICHAEL A. REED, BRUCE SAWYER, ANDREW C. STICKNEY and THOMAS M. BRUNELLE,

Defendants

ORDER ON MOTION TO STAY PROCEEDINGS AND COMPEL ARBITRATION

This case is before the court on the Motion to Stay Proceedings and

Compel Arbitration filed by Defendant LPL Financial LLC ["LPL"], along with the

Plaintiffs' opposition thereto, and LPL's reply . Also before the court is Plaintiffs'

Motion for Expedited Discovery, Depositions and Interrogatories, with

Defendants' opposition thereto.

The court elects to decide both motions without oral argument. See M.R.

Civ. P. 7(b)(7) .

Background:

According to Plaintiffs' Complaint 1 in this case, Plaintiff William Temm is a

certified financial advisor with more than 30 years of experience, and is married

1 Plaintiffs filed an Amended Complaint after the Defendants had served responsive pleadings, without filing a motion for leave to amend. See M.R. Civ. P. 15(a). If the Plaintiffs wish their Amended Complaint to be considered in this case, they will need to file a motion for leave to amend.

1 to Plaintiff Dale Temm. In 2002, William Temm and Defendants Michael Reed,

Bruce Sawyer and Andrew Stickney formed TRSS Wealth Management LLC, a

firm providing financial advisory and management services. Shortly thereafter,

Mr. Temm and the others each entered into a Representative Agreement with

LPL, which is a broker dealer in securities.

Plaintiffs' Complaint alleges that the Defendants are liable for a variety of

wrongful acts and omissions involving William Temm. Dale Temm asserts

derivative claims for loss of consortium.

Defendant LPL's Motion to Stay Proceedings and Compel Arbitration

asserts that Mr. Temm's Representative Agreement with LPL contains a

mandatory arbitration clause, and is supported by an affidavit incorporating a

copy of the Representative Agreement. See Affidavit of Brad Jacobs, Ex. A,

section 7(C).

Plaintiffs' Motion to Expedite Discovery is based on Mr. Temm's allegation

that he has been diagnosed with amyotrophic lateral sclerosis (ALS), and may

have only a short time left to live. He also asserts that the ALS diagnosis is a

reason not to compel him to submit his claims against LPL to arbitration.

Analysis

1. LPL Motion to Stay Proceedings and Compel Arbitration

As a prefatory matter, it should be noted that whether to enforce the

arbitration provision on which LPL relies is to be decided under Maine law, to be

determined under the Maine Arbitration Act and the jurisprudence associated

with it, see 14 M.R.S. §§5927 et seq., whereas interpretation of the arbitration

provision and other provisions of the Representative Agreement is governed by

2 Massachusetts law. The Representative Agreement between LPL and Mr.

Temm recites that it is to be construed in accordance with Massachusetts law.

See Affidavit of Brad Jacobs, Ex. A, section 7(8).

The Maine Arbitration Act provides, in pertinent part: "A written agreement

to submit any existing controversy to arbitration or a provision in a written

contract to submit to arbitration any controversy thereafter arising between the

parties is valid, enforceable and irrevocable, save upon such grounds as exist at

law or in equity for the revocation of any contract." 14 M.R.S. § 5927.

LPL's Motion establishes that Mr. Temm's written contract with LPL

contains the following arbitration provision:

Representative hereby expressly agrees to submit to final and binding arbitration before the National Association of Securities Dealers, Inc. any and all disputes, claims or controversies relating to Representative's association with or termination from LPL. Representative expressly gives up the right to sue in a court of law or equity, including the right to trial by jury. Specific examples of disputes, claims or controversies that are required to be arbitrated include, but are not limited to, allegations of unlawful termination, sexual or racial harassment or discrimination on the job, gender discrimination, and claims of age or handicap discrimination.

Affidavit of Brad Jacobs, Ex. A, section 7(C).

Section 7(C) is obviously an arbitration provision in a written contract for

purposes of section 5927 of the Maine Arbitration Act. Moreover, all of the

Plaintiffs' claims against LPL are within the scope of section 7(C), in that all of the

claims "relat[e] to [Mr. Temm's] association with or termination from LPL."

Therefore, if section 7(C) is enforceable, all of the Plaintiffs' claims are subject to

mandatory binding arbitration, and cannot be pursued independently in this case.

If section 7(C) is enforceable, the arbitration would occur under the aegis

of the Financial Industry Regulatory Authority (FINRA). Plaintiffs in their

3 opposition memorandum refer repeatedly to the FINRA website, www.finra.org .

FINRA has a detailed structure and process for arbitration claims, including

separate arbitration codes for customers (i.e. investors not affiliated with the

securities industry) and industry professionals and entities.

However, Plaintiffs contend that the arbitration agreement reflected in

section 7(C) should not be enforced against them. Plaintiffs' primary basis for

opposing a stay of this case is that the arbitration clause is procedurally and/or

substantively unconscionable.

Under Maine law, "[u]nconscionability is a defense to the enforcement of

an arbitration provision. The basic test for unconscionability is whether, given the

parties' general commercial background and the commercial needs of the

particular trade or case, the clause involved is so one-sided that it is

unconscionable under the circumstances existing when the parties made the

contract." Stenzel v. Dell, Inc., 2005 ME 37, ,r2s, 870 A.2d 133, 143, quoting In

re FirstMerit Bank, N.A., 52 S.W.3d 749, 757, 44 Tex. Sup. Ct. J. 900 (Tex. 2001)

(internal quotation and citation omitted).

Procedural unconscionability focuses on the circumstances surrounding

the formation of the agreement to arbitrate. See Stenzel at ,r2s, 870 A.2d at 143

Substantive unconscionability focuses on the fairness of the arbitration

agreement. Stenzel at ,I27, 870 A.2d at 143.

Plaintiffs' procedural unconscionability claim boils down essentially to the

contention that the Representative Agreement between Mr. Temm and LPL is a

contract of adhesion rather than the product of negotiation . In Stenzel v. Dell,

Inc. , the Law Court defined a contract of adhesion as a "standardized contract

4 [form] offered to consumers of goods and services on an essentially 'take it or

leave it' basis which limits the duties and liabilities of the stronger party." Id. ,r26,

870 A.2d at 143, quoting Melody Home Mfg. Co. v. Barnes, 741 S.W.2d 349,

355, 31 Tex. Sup. Ct. J. 47 (Tex. 1987).

The Representative Agreement does appear to be a standardized

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