Theresa Nicholson, Jonathan Nicholson; Joshua Nicholson, & Jacquelyn N. Shoemaker v. Steven L. Brown, Kody Brown, Kristopher Brown, & Poverty Point Produce Co.

CourtLouisiana Court of Appeal
DecidedFebruary 26, 2025
Docket56,114-CA
StatusPublished

This text of Theresa Nicholson, Jonathan Nicholson; Joshua Nicholson, & Jacquelyn N. Shoemaker v. Steven L. Brown, Kody Brown, Kristopher Brown, & Poverty Point Produce Co. (Theresa Nicholson, Jonathan Nicholson; Joshua Nicholson, & Jacquelyn N. Shoemaker v. Steven L. Brown, Kody Brown, Kristopher Brown, & Poverty Point Produce Co.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Theresa Nicholson, Jonathan Nicholson; Joshua Nicholson, & Jacquelyn N. Shoemaker v. Steven L. Brown, Kody Brown, Kristopher Brown, & Poverty Point Produce Co., (La. Ct. App. 2025).

Opinion

Judgment rendered February 26, 2025. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 56,114-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

THERESA NICHOLSON, Plaintiffs-Appellants JONATHAN NICHOLSON, JOSHUA NICHOLSON, & JACQUELYN N. SHOEMAKER

versus

STEVEN L. BROWN, KODY Defendants-Appellees BROWN, KRISTOPHER BROWN, & POVERTY POINT PRODUCE CO.

Appealed from the Fifth Judicial District Court for the Parish of West Carroll, Louisiana Trial Court No. 31,996

Honorable Will Barham, Judge

HUDSON, POTTS & BERNSTEIN, LLP Counsel for Appellants By: Robert M. Baldwin G. Adam Cossey Jason R. Smith

OFFICES OF BRIAN CRAWFORD, LLC Counsel for Appellees

Before STONE, COX, and STEPHENS, JJ. STEPHENS, J.,

The instant appeal is from the trial court’s adverse judgment which

granted an exception of no cause of action filed by the defendants, Steven

Brown and Poverty Point Produce Company. For the reasons set forth

below, we reverse the trial court’s judgment and remand the matter to the

trial court for further proceedings.

FACTS/PROCEDURAL BACKGROUND

This action began when the plaintiffs, Theresa Nicholson and her

three children (“the Nicholsons”), owners of 50% of the shares in a small,

closely held family corporation, filed suit against the owners of the

remaining shares, the defendants, her brother Steven Brown and his children

(“the Browns”). The Nicholsons’ first petition, filed on October 5, 2020,

alleged the invalidity of a “Unanimous Consent Resolution” (“UCR”),

claimed a deadlock between the members of Poverty Point Produce

Company (“PPP”), which would require dissolution of the company, and

sought withdrawal from the corporation as “Oppressed Shareholders.”

Mediation was attempted with no resolution. The Nicholsons filed a

“Supplemental, Amended and Restated Petition” on May 23, 2023. The

defendants then filed exceptions of no cause and no right of action and

vagueness to the second petition on August 22, 2023. After a hearing, the

trial court ruled in favor of the defendants1 by sustaining the exception of no

cause of action and dismissing the plaintiffs’ claims with prejudice without

By this time, Brown and PPP were the only remaining defendants, his sons 1

Kody Brown and Kristopher Brown having been dismissed by consent of the parties. leave to amend by judgment signed on May 28, 2024, and filed on May 31,

2024. It is from this judgment that the Nicholsons have appealed.

As this is an appeal from a judgment sustaining an exception of no

cause of action, the relevant facts are taken from the plaintiffs’ second

petition. These facts2 are:

• Theresa Nicholson, Jonathan Nicholson, Joshua Nicholson, and Jacquelyn Shoemaker (“the Nicholsons”) and Steven Brown, Kody Brown, and Kristopher Brown (“the Browns”) are the sole shareholders of Poverty Point Produce Company (“PPP”).

• Theresa Nicholson and Steven Brown are the directors of PPP.

• The Nicholsons own 300 shares of the Company, and the Browns own 300 shares of PPP.

• In August 2013, Theresa Nicholson and Steven Brown executed a UCR.

• In May 2014, Steven Brown, Kody Brown, and Kristopher Brown executed a UCR.

• In February 2016, all directors and shareholders of PPP executed a UCR.

• The 2014 and 2016 UCRs were substantially similar and/or identical to the 2013 UCR.

• The UCRs gave Steven Brown substantial corporate power, including those corporate powers traditionally and legally reserved for the Board of Directors.

• The sole reason the plaintiffs agreed to sign the UCRs was they were informed by Steven Brown that it was necessary to get a sweet potato purchase contract with ConAgra which was essential to the business of PPP.

• The plaintiffs “now think that the assertion by Steven L. Brown concerning the ConAgra contract” was false and the real reason for Brown to take control of the company was for his advantage and that of his family.

2 Legal theories of recovery or argument set forth in the plaintiffs’ petition are omitted. 2 • The sole and only cause for the plaintiffs’ execution of the agreements was the false statement that they were required to get the ConAgra contracts.

• Steven L. Brown effectively usurped the powers guaranteed to the Board of Directors via the UCRs. The UCRs limited the directors’ independent responsibility for corporate management, forced the Board of Directors to abdicate its functions and fiduciary duties, and interfered with the unfettered discretion of the Board of Directors to manage the corporation as the Board saw fit.

• The UCRs do not state that they are unanimous governance agreements or that they are governed by La. R.S. 12:1-732.

• Due to the status of the directors and shareholders described above, the directors are deadlocked in voting power in the management of the corporate affairs, the shareholders are unable to break the deadlock because they are deadlocked in voting power, and the business and affairs of the corporation can no longer be conducted to the advantage of the shareholders generally.

• Plaintiffs believe that discovery will also show that the shareholders are deadlocked in voting power and have failed, for a period that includes at least two consecutive annual meeting dates, to elect successors to directors whose terms have expired.

• Historically, PPP’s shareholders, including the plaintiffs, collectively enjoyed shared management and oversight of PPP.

• Due to the Browns’ actions, including but not necessarily limited to, coercing the plaintiffs into executing the UCRs, the Browns have seized total practical control of PPP.

• The Browns and some of the plaintiffs have historically, through 2019, enjoyed employment with PPP. However, in 2020, Steven Brown first reduced the plaintiffs’ employment, then terminated it abruptly and without cause, while the Browns remained employed by PPP with “increasingly exorbitant salaries, vehicles, and fuel paid for” by PPP and other benefits of employment that are not commensurate with those benefits and salaries of previous employees of PPP, including the plaintiffs.

• The course of behavior by the Browns on behalf of PPP has been a systematic process to effectively eliminate the plaintiffs from having any control, management, oversight, or say so in PPP.

3 DISCUSSION

Plaintiffs’ Argument

According to the Nicholsons, while the alleged facts are simple, the

second petition specifically and clearly lays out sufficient facts that give rise

to several causes of action. First, the second petition alleges that the UCRs

executed by the plaintiffs are invalid because they do not comply with the

statutory requirements of Louisiana law regarding Unanimous Governance

Agreements (“UGA”). If the UCRs are not UGAs as alleged, they cannot,

as a matter of law, act to take away the governance rights of Theresa

Nicholson as a director, or any of the shareholders, urge the plaintiffs.

The plaintiffs’ second petition alleges that the UCRs do not state that

they are unanimous governance agreements or that they are governed by La.

R.S. 12:1-732. This statute requires that either of these statements be in a

UGA for it to be valid. As the Nicholsons have alleged, however, the UCRs

do not do so. Clearly they have alleged a cause of action for the invalidity of

the UCRs, urge the plaintiffs.

A related complaint asserted by the plaintiffs is that the trial court

improperly analyzed the validity of the UCRs. First, the trial court

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Theresa Nicholson, Jonathan Nicholson; Joshua Nicholson, & Jacquelyn N. Shoemaker v. Steven L. Brown, Kody Brown, Kristopher Brown, & Poverty Point Produce Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/theresa-nicholson-jonathan-nicholson-joshua-nicholson-jacquelyn-n-lactapp-2025.