The Water Works and Sewer Board of the City of Prichard v. Synovus Bank (Appeal from Mobile Circuit Court: CV-23-901332).

CourtSupreme Court of Alabama
DecidedMay 17, 2024
DocketSC-2023-0881
StatusPublished

This text of The Water Works and Sewer Board of the City of Prichard v. Synovus Bank (Appeal from Mobile Circuit Court: CV-23-901332). (The Water Works and Sewer Board of the City of Prichard v. Synovus Bank (Appeal from Mobile Circuit Court: CV-23-901332).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Water Works and Sewer Board of the City of Prichard v. Synovus Bank (Appeal from Mobile Circuit Court: CV-23-901332)., (Ala. 2024).

Opinion

Rel: May 17, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2023-2024

_________________________

SC-2023-0881 _________________________

The Water Works and Sewer Board of the City of Prichard

v.

Synovus Bank

Appeal from Mobile Circuit Court (CV-23-901332)

SELLERS, Justice.

The Water Works and Sewer Board of the City of Prichard ("the

Board") appeals from an order of the Mobile Circuit Court appointing a SC-2023-0881

receiver to administer and operate the Board's waterworks and sewer

system ("the system"). We affirm.

I. Facts and Procedural History

On November 1, 2019, the Board entered into a trust indenture

("the indenture") with Synovus Bank, pursuant to which Synovus agreed

to serve as the trustee for the Board's issuance of $55.78 million in "Series

2019 Bonds." The Board issued the bonds to refund its existing "Series

2018 Bonds" and to fund capital improvements for the aging

infrastructure of the system. 1 Section 12.1 of the indenture defines the

various circumstances that constitute an "event of default" under the

indenture. The indenture also sets forth the rights and remedies

available to the trustee upon the "occurrence and continuation" of any

default. Relevant here, § 12.2(c) of the indenture provides:

"The Trustee shall be entitled upon or at any time after the commencement of any proceedings instituted with respect to an Event of Default, as a matter of strict right, upon the order of any court of competent jurisdiction, to the appointment of a receiver to administer and operate the System, with power to fix and charge rates and collect revenues sufficient to provide

1In its "Official Statement" to prospective bondholders, the Board

represented that approximately $22.8 million of the proceeds of the bonds would be applied to the redemption of previously issued Series 2018 bonds and that the remaining balance would be used to fund capital improvements. 2 SC-2023-0881

for the payment of the Bonds and any other obligations outstanding against the System or the revenues thereof and for the payment of expenses of operating and maintaining the System and with power to apply the income and revenues of the System in conformity with the Indenture."

(Emphasis added.)

In June 2023, Synovus, in its capacity as the trustee under the

indenture ("the trustee"), commenced a breach-of-contract action against

the Board, alleging that the Board had defaulted in several respects

under the indenture and requesting, among other things, the

appointment of a receiver pursuant to § 12.2(c) of the indenture. In its

complaint, the trustee maintained that a receiver was necessary not only

because the Board had defaulted under the indenture, but also because

the system was suffering from "gross mismanagement, a lack of fiscal

integrity, and endangering public safety by failing to maintain vital

system infrastructure." The trustee also filed an emergency motion,

requesting that the trial court appoint John S. Young, Jr., LLC ("Young"),

as the receiver to administer and operate the system.2

2The indenture defines "System," in relevant part, as "the entire

water supply and distribution system and sanitary sewer system owned by the Board."

3 SC-2023-0881

Following a two-day hearing, the trial court entered a detailed

order, finding that the Board was in default of numerous provisions of

the indenture and that it had not diligently pursued appropriate

corrective action for those defaults. 3 The trial court appointed Young

("the receiver") to administer and operate the system. In its order, the

trial court found that the trustee was entitled to the appointment of a

receiver based solely on § 12.2(c) of the indenture. However, the trial

court also found other compelling circumstances that justified the

appointment of a receiver:

"As a result of years of mismanagement and fiscal irresponsibility, [the Board's] assets have dissipated and fallen into ruin. The undisputed evidence showed that 60% of the water purchased by [the Board] is lost through the [Board's] dilapidated … system before it reaches its consumers. That is a staggering figure, and it constitutes compelling evidence that the system is in crisis -- without regard to the fiscal fraud, theft and abuse which occurred on [the Board's] watch. This is not a situation where a natural disaster (hurricane, earthquake, etc.) caused immediate and unforeseen damage to the infrastructure of [the system], but instead, the dilapidated state of [the Board's] system is the

3The defaults included the Board's failure to make the full interest

payment due on the bonds on May 1, 2023; to replenish the reserve fund after money in that fund was used to make the May 1, 2023, interest payment on the bonds; to reimburse the reasonable fees of the trustee and the trustee's attorney; to provide audits of its books and records; and to fix and maintain rates sufficient to provide annual net income to satisfy its debt obligations on the bonds. 4 SC-2023-0881

result of years of poor planning, mismanagement or worse. Consequently, when seeking a badly needed bond issue, [the Board] undoubtedly had no choice but to agree to the terms of the Indenture which provided for the appointment of a receiver upon the occurrence of any contractual default. The evidence also showed that bond proceeds of the Indenture, which were earmarked for specific capital improvements, were mostly used as operational funds. That is, very little of the bond money received in 2019 was actually used for the capital improvements designated in the Indenture. Accordingly, the Court finds that the Trustee was entitled to seek this remedy, and the Court further finds that irreparable harm will occur through the dissipation and wasting of [the Board's] assets if a receiver is not appointed by the Court."

The trial court further determined that there was no other adequate

remedy at law for the injuries the trustee would suffer absent the

appointment of a receiver. The Board appealed. See Rule 4(a)(1)(B), Ala.

R. App. P. (permitting appeal of "interlocutory order appointing … a

receiver").

II. Standard of Review

"Because the trial court heard 'live' testimony at the hearing it conducted in this case, we review its findings of fact under the ore tenus standard of review. ' "Under the ore tenus rule, a trial court's findings of fact are presumed correct and its judgment will be reversed only if plainly or palpably wrong or against the preponderance of the evidence." ' Ex parte Baron Servs., Inc., 874 So. 2d 545, 548 (Ala. 2003) (quoting Ex parte Cater, 772 So. 2d 1117, 1119 (Ala. 2000)). '[T]he ore tenus rule does not extend to cloak a trial judge's conclusions of law ... with a presumption of correctness.' Baron, 874 So. 2d at 549 (quoting Eubanks v. Hale, 752 So. 2d 1113

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The Water Works and Sewer Board of the City of Prichard v. Synovus Bank (Appeal from Mobile Circuit Court: CV-23-901332)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-water-works-and-sewer-board-of-the-city-of-prichard-v-synovus-bank-ala-2024.