WAKA, L.L.C. v. Humphrey

73 Va. Cir. 310, 2007 Va. Cir. LEXIS 96
CourtFairfax County Circuit Court
DecidedMay 2, 2007
DocketCase No. 2006-14305
StatusPublished
Cited by2 cases

This text of 73 Va. Cir. 310 (WAKA, L.L.C. v. Humphrey) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WAKA, L.L.C. v. Humphrey, 73 Va. Cir. 310, 2007 Va. Cir. LEXIS 96 (Va. Super. Ct. 2007).

Opinion

By Judge Leslie M. Alden

This matter came before the Court on January 26,2007, upon Messrs. Walicek, Lowiy, and LeHane’s demurrer to Mr. Humphrey’s Third-Party Complaint stating a direct claim for breach of fiduciary duty. At the conclusion of the hearing, the Court took the demurrer to Count m under advisement and granted the parties leave to submit supplemental briefs. The parties were instructed to address whether the managers, members, and member-managers of a limited liability company owe fiduciary duties to one another. For the reasons stated below, the demurrer is sustained.

I. Facts

The facts are presented as alleged in Mr. Humphrey’s Counterclaim and Third-Party Complaint and are taken as true for purposes of review of the demurrer.

WAKA, L.L.C. (“WAKA”) is a member-managed Virginia Limited Liability Company created on January 1,2003. Counterclaim and Third-Party Claim, ¶¶ 10,13. Mr. Humphrey and Messrs. Walicek, LeHane, and Lowry [311]*311(“Majority Members”) were the four original member-managers. Id. at ¶¶ 11, 12. On April 3, 2006, the Majority Members terminated Humphrey’s membership in the L.L.C. on the ground that Humphrey had failed to pay a required capital contribution or perform equivalent services to the L.L.C. as specified in the L.L.C. operating agreement. Id. at ¶¶ (25)(e)-(f). On November 14,2006, WAKA initiated litigation against Humphrey for alleged violations of the Virginia Computer Crimes Statute and other alleged misconduct. Id. at ¶ 31.

Humphrey, by Counterclaim and Third-Party Claim, seeks a declaratoiy judgment to determine the rights and interests of the WAKA members. Id. at ¶¶ 33-36. Humphrey additionally asserts claims against the Majority Members for breach of fiduciary duty (direct and derivative claim), breach of operating agreement (direct and derivative claim), statutory business conspiracy, common law business conspiracy, and unjust enrichment. Id. at ¶ 37-75.

Count III alleges that the Majority Members individually breached the fiduciary duty owed to Humphrey as a member of WAKA. The Majority Members demur to Count in and contend that, as managers, their sole fiduciary duty is to the L.L.C. as an entity, not to Humphrey as an individual member.

II. Arguments in Support of And in Opposition to the Demurrer

The Majority Members contend that the Virginia Limited Liability Company Act, Va. Code §§ 13.1-1000 et seq. (“L.L.C. Act”), defines the scope of fiduciary duties owed by L.L.C. managers. The L.L.C. Act establishes that a manager of an L.L.C. owes a duty to the company, but the L.L.C. Act does not impose fiduciary obligations towards, among, or between members. See Va. Code § 13.1-1024.1. Unlike the Virginia Uniform Partnership Act, Va. Code §§ 50-73.79 et seq. (“Partnership Act”), which expressly defines partners’ fiduciary duties to the partnership and to the other partners, the L.L.C. Act is silent in this regard. See Va. Code § 50-73.102. Relying on Halifax Corp. v. Wachovia Bank, 268 Va. 641, 604 S.E.2d 403 (2004), the Majority Members argue that the absence of an express provision defining fiduciary obligations among L.L.C. members signifies the legislature’s intent not to impose fiduciary duties among L.L.C. members.

Humphrey argues that a member-managed L.L.C., as distinct from a manager-managed L.L.C., operates essentially as a general partnership and, therefore, L.L.C. member-managers owe common law fiduciary duties to L.L.C. members. Humphrey cites a number of decisions from foreign [312]*312jurisdictions which recognize partnership-type fiduciary standards in the L.L.C. context. Humphrey argues that the statutory construction framework of Halifax is inapposite to this case, because in Halifax, the Virginia Supreme Court construed component parts of a contemporaneously enacted statute, whereas here, the Majority Members compare two different statutes adopted four years apart.

HI. Legal Discussion

A demurrer tests the legal sufficiency of the claims stated in the pleading challenged. Dray v. New Market Poultry Products, Inc., 258 Va. 187, 189, 518 S.E.2d 312 (1999). The sole question to be decided by the court is whether the facts pleaded, implied, and fairly and justly inferred, are legally sufficient to state a cause of action against Defendant. Thompson v. Skate America, Inc., 261 Va. 121, 128, 540 S.E.2d 123 (2001). In considering a demurrer, a court accepts as true all material facts expressly alleged and all reasonable inferences which may fairly be drawn from these facts. Russo v. White, 241 Va. 23, 24, 400 S.E.2d 160 (1991). A demurrer, however, does not admit as true a pleader’s conclusions of law. Id.

To assess the legal sufficiency of Humphrey’s claim in Count IH, this Court must determine whether, as a matter of law, member-managers of a L.L.C. owe fiduciary duties to the L.L.C.’s members in addition to the fiduciary duty member-managers owe to the L.L.C.

Duties of L.L.C. members can be defined in three places: (1) the articles of organization, (2) an operating agreement, or (3) The L.L.C. Act. WAKA’s articles of incorporation and operating agreement are silent regarding fiduciary duties among members; therefore, resort must be made to the statutory standard. Operating Agreement, CC&TPC Ex. 2; Broyhill v. DeLuca, 194 B.R. 65 (Bankr. E.D. Va. 1996). The L.L.C. Act, Va. Code §§ 13.1-1000 et seq., provides a general standard of conduct for L.L.C. managers. Pursuant to § 13.1-1024.1, a “manager shall discharge his or its duties as a manager in accordance with the manager’s good faith business judgment of the best interests of the limited liability company.” The remainder of Article 5, “Relationship of Members to Each Other,” §§ 13.1-1022 to 13.1-1028 is silent regarding fiduciary obligations among L.L.C. members.

Since the enactment of the L.L.C. Act in 1991, there have been few interpretive decisions defining the statutory standards of conduct for a manager. In Flippo v. CSC Assoc. III, L.L.C., 262 Va. 48, 547 S.E.2d 216 (2001), the Virginia Supreme Court held that aL.L.C. manager breached his fiduciary duty to the L.L.C. when he transferred the L.L.C.’s assets to a [313]*313newly-formed company to protect his own estate planning interests. 262 Va. at 57. The Court analogized an L.L.C. manager’s duty of care to that of a corporate director, noting that the statutory language defining the standard of conduct for L.L.C. managers was almost identical to the statutory language defining the standard of conduct for corporate directors. 262 Va. at 56-57. Compare the duty owed by a corporate director, “A director shall discharge his duties as a director, including his duties as a member of a committee, in accordance with his good faith business judgment of the best interests of the corporation,” Va. Code § 13.1-690, with Va.

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Bluebook (online)
73 Va. Cir. 310, 2007 Va. Cir. LEXIS 96, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waka-llc-v-humphrey-vaccfairfax-2007.