Travelers Casualty and Surety Company of America v. Decker

CourtDistrict Court, W.D. Washington
DecidedOctober 28, 2024
Docket2:24-cv-00253
StatusUnknown

This text of Travelers Casualty and Surety Company of America v. Decker (Travelers Casualty and Surety Company of America v. Decker) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Travelers Casualty and Surety Company of America v. Decker, (W.D. Wash. 2024).

Opinion

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5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 TRAVELERS CASUALTY AND CASE NO. 2:24-cv-00253-TL SURETY COMPANY OF AMERICA, a 12 Connecticut corporation, ORDER ON MOTION TO DISMISS 13 Plaintiff, THIRD-PARTY COMPLAINT v. 14 JASON P. DECKER and DEBRA A. 15 DECKER, husband and wife and the marital community composed thereof, et 16 al., 17 Defendants. 18

19 This case arises from a chain reaction of events—the legality of which the Parties 20 dispute—set into motion when borrower Elcon Corporation, an Everett, Washington–based 21 electrical contractor, defaulted on a loan from lender KeyBank. Presently before the Court is a 22 motion to dismiss (Dkt. No. 46) brought by Third-Party Defendants KeyBank and Dale Conder, in 23 response to a Third-Party Complaint (Dkt. No. 20) filed by several Defendants named in the 24 1 original Complaint. Having considered the relevant record, the Court GRANTS the motion to 2 dismiss. 3 I. BACKGROUND 4 A. The Parties

5 The Third-Party Plaintiffs here are: (1) Jason P. Decker, Debra A. Decker, and the marital 6 community composed thereof; (2) WilDec, LLC; and (3) Decker & Williams, LLC. Dkt. No. 20 7 at 2. These plaintiffs represent a subset of the Defendants named in the original Complaint (Dkt. 8 No. 1).1 They also refer to themselves collectively as “the Decker Defendants.” Id. To maintain 9 consistency and continuity, the Court will do the same. 10 The Third-Party Defendants here are KeyBank, N.A., and Dale Conder. Id. Dale Conder 11 is employed by KeyBank as a Senior Vice President. Dkt. No. 20 ¶ D3. The Third-Party 12 Complaint includes two causes of action against both KeyBank and Mr. Conder, and one against 13 KeyBank exclusively. For their part, KeyBank and Mr. Conder defend themselves collectively 14 and treat their actions as one and the same. See generally Dkt. Nos. 20, 46. To maintain

15 consistency and continuity, the Court will thus refer to Third-Party Defendants KeyBank and 16 Dale Conder collectively as “KeyBank.” 17 B. Travelers’s Surety Bonds for Elcon 18 In July 2017, Plaintiff Travelers Casualty and Surety Company of America (“Travelers”) 19 issued surety bonds for Elcon Corporation (“Elcon”), an electrical subcontractor engaged in 20 several public-works projects in the Pacific Northwest. Dkt. No. 1 ¶¶ 10, 12, 21–22. In 21 connection with the bond issuance, numerous parties executed and delivered to Travelers a 22 General Agreement of Indemnity (“GAI”). Id. ¶ 10. Included within this group were: (1) Jason P. 23

24 1 Travelers Casualty and Surety Company of America is the original Plaintiff in this case. See Dkt. No. 1. 1 Decker, Debra Decker, and the marital community composed thereof;2 (2) Anthony Ray Schults, 2 Karen Koppel Schults, and the marital community composed thereof; (3) Scott Elden Wood, 3 Olivia Ferreira-Wood, and the marital community composed thereof; (4) Passage, Inc.; 4 (5) WilDec, LLC; and (6) Decker & Williams, LLC. Id. Under the GAI, these parties became

5 indemnitors for the surety bonds. Id. ¶ 13. The GAI obligates the indemnitors “to exonerate, 6 indemnify, and save Travelers harmless from and against all ‘Loss,’” as that term is defined in 7 the GAI. Id. ¶ 14; see id. ¶ 16. The GAI further obligates the indemnitors to, inter alia, “deposit 8 with [Travelers], upon demand, an amount as determined by [Travelers] sufficient to discharge 9 any Loss or anticipated Loss.” Id. ¶ 17. And the GAI requires the indemnitors to “furnish upon 10 demand” various records, “including but not limited to, books, papers, records, documents, 11 contracts, reports, financial information, accounts and electronically stored information.” Id. ¶ 18. 12 At some point during Summer 2023, a “loss,” as defined in the GAI, occurred, thereby 13 triggering the indemnitors’ obligations to Travelers under the GAI. Id. ¶¶ 23–26. In the original 14 Complaint, Travelers alleges that the indemnitors have not performed their obligations under the

15 GAI; Travelers seeks both legal and equitable relief. Id. ¶¶ 27–57. 16 C. KeyBank’s Loans to Elcon 17 In January 2022, Elcon signed a line-of-credit (“LOC”) loan with KeyBank to borrow up 18 to the principal amount of $7,000,000. Dkt. No. 20 ¶¶ D4, 5. In July 2022, Elcon signed a 19 business loan agreement with KeyBank, which had the effect of extending the maturity date of 20 the LOC loan by approximately one year. Id. ¶ D5. In the business loan agreement, Elcon 21 22 23

24 2 Jason Decker is the 49 percent minority owner of Elcon Corporation. Dkt. No. 20 ¶ D1. 1 “agreed to make mandatory payments [to KeyBank] at any time the aggregate principal amount 2 of the Loan exceeded Elcon’s ‘Borrowing Base.’”3 Id. ¶ D6. 3 On April 24, 2023, KeyBank issued Elcon a “Notice of Default.” Id. ¶ D9. In the Notice 4 of Default, KeyBank claimed that “Elcon lacked sufficient working capital to maintain the

5 Borrowing Base for its LOC.” Id. Elcon does not appear to have disputed the propriety or 6 accuracy of the Notice of Default. Upon the issuance of the Notice of Default, KeyBank and 7 Elcon began negotiations over Elcon’s response, in part to “facilitate a reasonably prompt cure of 8 the Existing Defaults.” Id. 9 By June 7, 2023, these negotiations between Elcon and KeyBank appear to have broken 10 down. Id. ¶ D12. At a Zoom meeting held on that date, “KeyBank threatened to issue a UCC 9- 11 607 Notice[4] . . . to Elcon’s upstream contract, Absher [Construction Company], directing 12 Absher to withhold all contract receivables from Elcon and instead turn them over to KeyBank.” 13 Id. Elcon protested and advised KeyBank that issuing the 9-607 Notice was “against Key’s own 14 interest.” Id. Elcon reminded KeyBank of Travelers’s surety bonds and advised that those bonds

15 gave Travelers priority over KeyBank in the event of a creditors’ run on Elcon. Id.; see id. ¶ D13 16 (“It is further noteworthy that the Travelers GIA has been in existence long before the KeyBank 17

3 A “borrowing base” is an amount of collateral used as a baseline to calculate the amount of a borrower’s line of 18 credit. See Radish Seed Growers Ass’n v. Nw. Bank, No. C17-716, 2017 WL 6048169, at *3 (D. Or. Oct. 3, 2017). In the agreement between Elcon and KeyBank, the borrowing base was the lesser of $7,000,000 or 85 percent of the 19 aggregate amount of Elcon’s “Eligible Accounts.” Dkt. No. 46-4 at 8. 4 Within the context of secured transactions, a “9-607 Notice” refers to Article 9, Section 607, of the Uniform 20 Commercial Code (“U.C.C.”). In Washington, the U.C.C. is codified in Title 62A of the Revised Code of Washington; Section 9-607 is located at RCW 62A.9A-607. Under U.C.C. 9-607, in the event of a debtor’s default, 21 a secured creditor may “notify an account debtor or other person obligated on collateral to make payment or otherwise render performance to or for the benefit of the secured party.” RCW 62A.9A-607. Here, this meant that 22 KeyBank, as Elcon’s secured creditor, could instruct entities to whom Elcon was a subcontractor to pay KeyBank, not Elcon, for work that Elcon performed on their contract. Importantly, as a practical effect of receiving a 9-607 Notice, a third party with whom the defaulting debtor has a contract necessarily learns of the default and, 23 consequently, may: (1) surmise that the defaulting debtor is experiencing financial difficulty; (2) if contractually appropriate, declare the defaulting debtor to be in default of its contract with the third party; and/or (3) take other 24 steps to protect its interests, pursuant to its contract with the defaulting debtor.

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Travelers Casualty and Surety Company of America v. Decker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/travelers-casualty-and-surety-company-of-america-v-decker-wawd-2024.