Wells Fargo Bank, N.A. v. Equiniti Trust Company

CourtDistrict Court, D. Delaware
DecidedFebruary 2, 2026
Docket1:22-cv-01586
StatusUnknown

This text of Wells Fargo Bank, N.A. v. Equiniti Trust Company (Wells Fargo Bank, N.A. v. Equiniti Trust Company) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wells Fargo Bank, N.A. v. Equiniti Trust Company, (D. Del. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WELLS FARGO BANK, N.A., Plaintiff, v. Civil Action No. 22-1586-GBW EQUINITI TRUST COMPANY, Defendant.

J. Cory Falgowski, BURR & FORMAN LLP, Wilmington, DE; Christian Kemnitz, KATTEN MUCHIN ROSENMAN LLP, Chicago, IL; Rebecca K. Lindahl, KATTEN MUCHIN ROSENMAN LLP, Charlotte, NC. Counsel for Plaintiff Dominick T. Gattuso, HEYMAN ENERIO GATTUSO & HIRZELL LLP, Wilmington, DE; John T. Zach, Sabina Mariella, BOIES SCHILLER FLEXNER LLP, New York, NY. Counsel for Defendant

MEMORANDUM OPINION February 2, 2026 Wilmington, Delaware

be \. a \ WS ' GREGORY B. WILLIAMS UNITED STATES DISTRICT JUDGE Pending before the Court are four motions for summary judgment filed by Defendant Equiniti Trust Company, LLC (“Equiniti”), including Equiniti’s Motion for Summary Judgment #1 on Plaintiff's Negligent Misrepresentation Claim (D.I. 87), which is fully briefed (D.1. 89; □□□□ 111; D.1. 136); Equiniti’s Motion for Summary Judgment #2 on Plaintiff's UCC Claim (D.1. 90), which is fully briefed (D.I. 92; D.I. 114; D.I. 138); Equiniti’s Motion for Summary Judgment #3 on Plaintiff's Breach of Contract Claim (D.I. 93), which is fully briefed (D.I. 95; D.I. 117; D.L. 140); and Equiniti’s Motion for Summary Judgment #4 on Plaintiff's Contractual Indemnification Claim (D.I. 96), which is fully briefed (D.I. 98; D.I. 120; D.I. 142) (collectively, “Equiniti’s Motions for Summary Judgment’). The Court has reviewed the relevant briefing, accompanying exhibits, and declarations and for the reasons stated below, the Court grants Equiniti’s Motions for Summary Judgment. I BACKGROUND This action arises from Equiniti’s alleged failure, in its capacity as transfer agent, to timely process and execute Plaintiff Wells Fargo Bank N.A.’s (“Wells Fargo”) requests to sell shares of Occidental Petroleum Corporation (“Occidental”) stock. The following facts are undisputed unless otherwise noted. A. Formation of the Trust Agreement & Transfer Agent Service Agreement On May 15, 1995, Anadarko Petroleum Corporation (“Anadarko”) and Wachovia Bank of North Carolina, N.A. (“Wachovia”)! entered into the Anadarko Benefits Trust Agreement (“Trust

' For clarity and consistency, the Court will, from this point forward, refer to the parties by their current names, as Wells Fargo is the successor in interest to Wachovia (D.1. 1 §[ 10), and Occidental acquired Anadarko in August 2019 (D.1. 1 § 11).

Agreement”), which created a rabbi trust (the “Trust” for the benefit of Anadarko employees. See D.I. 99-15. On December 7, 2015, Occidental and Wells Fargo executed an agreement (the “Transfer Agent Services Agreement”), where Wells Fargo was to act as a transfer agent and provide services with respect to “the issuance, transfer and registration of securities of the Corporation.” D.I. 100- 1 at 2. B. Equiniti’s Assumption of the Transfer Agent Service Agreement On July 12, 2017, Wells Fargo entered into an agreement (the “Purchase Agreement”) to sell its transfer agent business, Shareholder Services, to Equiniti Group ple. D.I. 99-8. On January 31, 2018, Wells Fargo, Equiniti, and Equiniti Group ple executed an agreement (the “Joinder Agreement”), where Equiniti assumed and became responsible for all of Equiniti Group plc’s obligations under the Purchase Agreement. D.I. 99-17 at 3. The next day, on February 1, 2018, Wells Fargo, Equiniti Group plc, and Equiniti entered into an agreement (the “Bill of Sale, Assignment and Assumption Agreement”), where Equiniti assumed and agree to pay, perform and be responsible for, and discharge certain liabilities assigned by Wells Fargo. D.I. 99-17. Following the execution of the Purchase Agreement, Joinder Agreement and Bill of Sale, Assignment and Assumption Agreement, Equiniti assumed Wells Fargo’s obligations to Occidental and became Occidental’s transfer agent.

2 See Occidental Petroleum Corp. v. Wells Fargo Bank, N.A., 573 F. Supp. 3d 1161, 1163 (S.D. Tex. 2021) (“The agreement the parties entered is known as a rabbi trust because the first such agreement involved a rabbi. The agreement has nothing to do with the rabbinate and is in many ways unlike a conventional trust. A rabbi trust is essentially a bank account set up to hold money set aside for a company’s deferred compensation for high level executives, designed to minimize the tax impacts of setting aside the money. The structure used to achieve this tax avoidance uses the word trust, but it is more precisely a bank account in which a company puts money it commits to pay its executive employees and shields that money from certain tax consequences.”)

C. The Plan to Sell Occidental Stock & The Sale of Stock by Wells Fargo’s In-House Trading Desk On December 19, 2019, Occidental and Wells Fargo agreed to sell Occidental shares, commencing on January 6, 2020, with the sale of 381,420 shares per day throughout the week, and concluding with the final liquidation on January 10,2020. D.I. 100-3. A total of 1,907,100 shares were designated for sale, comprising 733,500 shares in street name registration’ held in Wells Fargo’s Depository Trust Company (“DTC”) account and 1,173,600 shares in direct registration’ with Equiniti. D.I. 100-4; D.I. 100-5. On January 6, 2020, Wells Fargo sold the first tranche of 381,420 shares, which were held in street name registration, through its in-house trading desk. D.I. 100-4. On January 7, 2020, Wells Fargo sold a second tranche of 352,080 shares, also held in street name registration, through its in-house trading desk. Jd, On the same day, Wells Fargo faxed Equiniti a Request Form requesting the sale of 29,430 shares (“January 7, 2020 Request”) that were held in direct registration with Equiniti®. D.I. 100-6.

3 There are three methods by which a shareholder may hold shares: physical certificate, street name registration and direct registration. See D.I. 1 § 35; D.I. 43 9 35. Street name registration “is registered in the name of the brokerage firm on the issuer’s books, and the brokerage firm holds the security for the shareholder in the book-entry form (meaning there is no physical certificate, but only an entry on the books denoting ownership).” Jd. 4 Direct registration “is registered in the shareholder’s name on the issuer’s books, and either the issuer or its transfer agent holds the security from the shareholder in book-entry form.” D.I. 1 735. > Shares held in direct registration may not be sold by the shareholder on the open market. Such shares may be sold through alternative methods, such as, “the shareholder uses a transfer agent to transfer the shares from the shareholder’s name to the Direct Registration System (“DRS”) into a brokerage account. Once the shares are transferred into street name and deposited in a brokerage account, a broker can sell the shares on the open market.” D.I. 1 37; D.L. 45 4 37.

D. The Sale of 29,430 Shares by Equiniti On January 8, 2020, Nikki Tanner (“Tanner”), Wells Fargo’s investment manager for the Trust, contacted Equiniti to inquire into the status of the January 7, 2020 Request. D.I. 100-6; D.I. 99-4 at 11:23-12:1; D.I. 99-5. Tanner spoke to Equiniti representative, Paul Beuning (“Beuning”), who stated that the request was “still active” and “still being processed . . . but it looks like it might not be accepted.” D.I. 99-5 at 4:10-15. When Tanner inquired as to why the request might not be accepted, Beuning stated that “[t]he reason J see is that it’s actually you need a medallion or a valid corporate resolution. The corporate resolution is missing a notary’s signature.” Jd. at 4:17-20. Beuning then placed Tanner on hold to reach out to another representative, Michelle, for clarification regarding the request. /d. at 6:11-10:19.

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Wells Fargo Bank, N.A. v. Equiniti Trust Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-na-v-equiniti-trust-company-ded-2026.