Worth v. Huntington Bancshares, Inc.

540 N.E.2d 249, 43 Ohio St. 3d 192, 1989 Ohio LEXIS 127
CourtOhio Supreme Court
DecidedJune 21, 1989
DocketNo. 88-185
StatusPublished
Cited by23 cases

This text of 540 N.E.2d 249 (Worth v. Huntington Bancshares, Inc.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Worth v. Huntington Bancshares, Inc., 540 N.E.2d 249, 43 Ohio St. 3d 192, 1989 Ohio LEXIS 127 (Ohio 1989).

Opinion

Wright, J.

We must decide two issues in the instant case. The first is whether the lower courts correctly held that Worth was not entitled to the economic benefits provided in his employment agreement. The second is whether Worth should be indemnified for his legal expenses regardless of his success in enforcing the other provisions of the agreement. We answer both questions in the affirmative. Accordingly, the judgment of the court of appeals is affirmed in part and reversed in part.

Worth’s employment agreement provided that it would be binding on the successors and assigns of both parties.1 Huntington does not dispute [194]*194that, as the successor to UCC, it is bound by the agreement. Thus, the question is whether Worth is entitled to recover under the terms therein, specifically under Sections 2 and 3.

Section 2 listed numerous benefits to which Worth would be entitled if his employment were terminated involuntarily within one year following a change in control. These benefits included two times his annual salary, payable in monthly installments over a two-year period; two times the amount he was to receive under the company’s Incentive Compensation Plan; comprehensive medical coverage for two years, or the cost thereof; payment for two years of club dues and special assessments; monthly payments for rental of an automobile; lump-sum cash payment for purchase of an annuity, or the benefits to which he has a vested right under the company’s pension plan; and the option to surrender his stock to the company for cash.2

Section 3 of the agreement provided as follows:

“3. Resignation Within Two [195]*195Years. In the event that Employee should determine in good faith that his status or responsibilities with the Company or UCB has or have diminished subsequent to a change in control, and shall for that reason resign from his employment with the Company or UCB within two years after such change in control, Employee shall be entitled to receive all of the payments and enjoy all of the benefits specified in Section 2 hereof.”

The parties agree that under the terms of the agreement a “change in control” occurred on July 2, 1982.3 Also undisputed is the fact that Huntington did not terminate Worth’s employment within the meaning of Section 2, but that Worth tendered his resignation within two years of the change in control as provided in Section 3. Thus the pivotal questions center on whether, under the language of Section 3, Worth made a good faith determination that his status and responsibilities had diminished, and whether such determination was the reason for his resignation.

The trial court determined that Worth’s responsibilities had not diminished following the takeover. In the court’s view, the fact that the importance of the energy division of HBNO was reduced in relation to other divisions and that Worth became less active in generating loan business did not constitute a diminution of responsibilities. As to Worth’s status, the [196]*196court indicated that all indicia of Worth’s status had remained the same or increased, but that since he had not been promoted to Chief of the Engineering Section he may have believed that there had been a slight diminution in his status. In any event, citing reasons other than those given by Worth for his decision, the court ruled that Worth had failed to prove that the diminution in status was his reason for resigning.

On appeal of these findings, Worth argued, inter alia, that the trial court had erroneously defined “status,” “responsibility,” and “diminished,” as those terms are used in the agreement, and that the court erred in ruling that his reasons for resigning were other than as he described. The court of appeals overruled both of these assignments of error, rejecting Worth’s argument that the basis for testing whether his determination that his status had diminished was made in good faith should be purely subjective, and that he had resigned solely because of such a determination.

We agree with the courts below that contractual obligations such as Worth’s employment agreement are valid and enforceable, an issue we expressly left open in our earlier review of this dispute. Worth v. Aetna Cas. & Sur. Co., supra, at 240, 513 N.E. 2d at 256, fn. 1. In upholding the agreement, the court of appeals overruled Huntington’s assignment of error on the issue, and Huntington has not appealed the issue to this court. Nevertheless, it is clear that resolution of this question is an implicit prerequisite to resolving the other issues presented. Accordingly, we must begin our analysis by addressing this threshold question.

This case presents the court with its first opportunity to address the enforceability of corporate employment agreements commonly known as “golden parachutes.” In general, “golden parachutes” are defined as “agreements between a corporation and its top officers which guarantee those officers continued employment, payment of a lump sum, or other benefits in the event of a change of corporate ownership.” Schreiber v. Burlington Northern, Inc. (1985), 472 U.S. 1, 3, fn. 2.

At trial in this case there was much concern over the use of the term “golden parachute” and its pejorative connotations. We see no problem with the use of that term in describing contracts such as the one at issue here. As other courts have noted, “[t]he term ‘golden parachute’ is not by itself legally significant, nor is it legally conclusive. It is merely descriptive of a certain type of employment contract given to top corporate executives * * *.” Koenings v. Joseph Schlitz Brewing Co. (1985), 126 Wis. 2d 349, 360, 377 N.W. 2d 593, 599. Accord Royal Crown Companies, Inc. v. McMahon (1987), 183 Ga. App. 543, 545, 359 S.E. 2d 379, 381.

Much has been written about this form of agreement, principally as to its use as a defense against hostile takeovers. See 2 Winter, Stumpf & Hawkins, Shark Repellants and Golden Parachutes: A Handbook for the Practitioner (1985) 432, fn. 1. Proponents of such contracts identify at least three primary benefits: (1) attraction and retention of competent managerial personnel, (2) promotion of executive objectivity by ensuring continued financial security, and (3) effective deterrence of hostile takeover attempts. Opponents argue that these potential benefits are illusory, and that golden parachutes operate solely for the benefit of executives and at the expense of shareholders. See, generally, Note, Koenings v. Joseph Schlitz Brew[197]*197ing Co.: The Wisconsin Supreme Court Addresses Executive Termination Benefits in a Golden Parachute Contract (1987), 1987 Wis. L. Rev. 823, 827-835; Note, Golden Parachutes and the Business Judgment Rule: Toward a Proper Standard of Review (1985), 94 Yale L.J. 909, 914-922 (hereinafter “Note, Golden Parachutes and the Business Judgment Rule”).

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Bluebook (online)
540 N.E.2d 249, 43 Ohio St. 3d 192, 1989 Ohio LEXIS 127, Counsel Stack Legal Research, https://law.counselstack.com/opinion/worth-v-huntington-bancshares-inc-ohio-1989.