West Virginia Business Litigation Lawyer & Attorney : Law Office of Jeffrey V. Mehalic : Charleston, Huntington, Parkersburg

    The Supreme Court of the United States will not hear an appeal from a verdict for $13 million returned by a Putnam County jury against Emerson Electric Co. and two of its subsidiaries, Daniel Measurement Services, Inc. and Daniel Industries, Inc.  The Court entered an order on Monday which denied DMS’ petition for a writ of certiorari, but which granted leave for the filing of several amici briefs on DMS’ behalf (page 12).

    The case started in 1999 when, in response to DMS’ request for proposal, Eagle bid on a contract for the manufacture of a flow computer, which would identify what is flowing through a pipe and measure the substance’s pressure without having to open the pipe.  As part of the bidding process, Eagle and DMS entered into a confidentiality agreement, whereby Eagle’s design could not be revealed.  Eagle was the low bidder, and entered into a contract with DMS to manufacture 3,000 of the units.

    Soon thereafter, Emerson bought DMS and obtained access to Eagle’s proprietary design information, which breached Eagle’s confidentiality agreement with DMS.  After an Emerson  employee disclosed the breach, Eagle filed suit in the Circuit Court of Putnam County against Emerson, DMS, and Daniel Industries.  (I understand that that disclosure also resulted in a lawsuit by Emerson against the employee.)

    Eagle claimed that Emerson’s conduct breached its confidentiality agreement with DMS.  Following a two week trial in 2006, a jury returned a verdict in Eagle’s favor for $14.8 million, of which $10.5 million represented damages for breach of the confidentiality agreement.

    The trial court reduced the verdict by $1.8 million, which the jury had awarded for Eagle’s lost profits on the sale of communications devices.  Eagle filed a petition for appeal with the Supreme Court of Appeals of West Virginia from that ruling, which was accepted by a vote of 5-0, but which Eagle subsequently withdrew.  DMS’ petition for appeal from the $13 million verdict was refused by the Supreme Court of Appeals by a vote of 3-2.

    I have not been able to obtain the parties’ briefs before either appellate court, but from reviewing the amicus brief filed by the Washington Legal Foundation on behalf of DMS, I gather that DMS’ petition for cert alleged that the verdict violated the Due Process Clause of the Fourteenth Amendment because there was no evidence in the record to support the verdict and because there was insufficient post-trial or appellate review of the verdict. 

    (The WLF brief asserted that “the West Virginia courts provided no meaningful review of the jury’s award.”   However, because the WLF, by its own admission, “regularly participates in tort reform efforts[,]” its view of the proceedings, particularly in West Virginia, the American Tort Reform Foundation’s “No. 1 Judicial Hellhole,”  makes it difficult, if not impossible, to get an accurate understanding of the parties’ positions on appeal.) 

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    I want to make a correction to my post last week about the Supreme Court’s decision reversing a $50 million verdict against A.T. Massey Coal Company and its subsidiaries.  I indicated that the trial was held in the Circuit Court of Lincoln County, which was incorrect. The trial was held in the Circuit Court of Boone County.  Sorry for any confusion.

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    Yesterday was the last day of the Supreme Court of Appeals of West Virginia’s Fall Term, and the Court released several opinions, including its decision in Caperton v. A.T. Massey Coal Company, Inc., No 33350. (The Westlaw opinion is not available yet, so the link is to the PDF version on the Court’s website.)

    At stake was the $50 million verdict in the plaintiffs’ favor, based on the jury’s finding that A.T. Massey Coal Company, Inc. and several of its subsidiaries intentionally interfered with and destroyed Hugh Caperton’s business.  With accrued interest since the verdict in 2002, the plaintiffs’ judgment had grown to approximately $76 million. Here’s my post from last month when the case was argued. 

    In a 3-2 decision written by Chief Justice Robin Davis, the Supreme Court reversed the verdict and remanded the case to the Circuit Court of Lincoln County with directions to enter an order dismissing with prejudice the plaintiffs’ claims against the defendants.  The Court identified two grounds for the reversal.  First, the circuit court should have granted the defendants’ motion to dismiss based on a forum selection clause contained in “a contract directly related to the conflict giving rise to the instant lawsuit.”  Second, assuming that the circuit court’s ruling on the forum selection clause was not erroneous, the Supreme Court found that the doctrine of res judicata based on an action that had been litigated in Virginia.

    The Virginia litigation to which the Court refers is the plaintiffs’ 1998 suit against a Massey subsidiary in the Circuit Court of Buchanan County, Virginia, which alleged breach of contract and breach of the duty of good faith and fair dealing.  Only the breach of contract claim was considered by the jury, which returned a verdict in the plaintiffs’ favor for $6 million.  That verdict resulted in Massey suing its Virginia counsel for malpractice, on the grounds that they failed to sign the notice of appeal, which resulted in the dismissal of the appeal and the affirmance of the verdict, which I also wrote about last month. 

    The first paragraph of the Court’s discussion will not provide any comfort to the plaintiffs: “At the outset we wish to make perfectly clear that the facts of this case demonstrate that Massey’s conduct warranted the type of judgment rendered in this case.  However, no matter how sympathetic the facts are, or how egregious the conduct, we simply cannot compromise the law in order to reach a result that clearly appears to be justified.  As we will demonstrate below, the law simply did not permit this case to be filed in West Virginia.”  So, if the Court had not reversed based on the forum selection clause and the doctrine of res judicata, it would have affirmed the verdict.

    Interestingly, the Court acknowledged that while the circuit court was correct in denying the defendants’ motion for summary judgment based on the doctrine of res judicata because the Virginia judgment was pending when the motion was filed, the Court concluded that it “may address the issue anew because a final judgment was rendered in the Virginia case by the time this appeal was prosecuted.” 

    Justices Larry Starcher and Joseph Albright filed separate dissenting opinions, which are here and here, both of which quote from the Court’s initial paragraph of its discussion, in which it affirms the factual basis for the jury’s verdict.  The Albright dissent points out that the majority opinion created seven new syllabus points having to do with forum selection clauses “applied to the facts of this case so as to relieve the defendants in excess of a verdict in excess of $50 million, plus interest and costs, which would have resulted in a judgment calculated to be in excess of $75 million.”

    The Starcher dissent focuses on jury’s assessment of the conduct of Don Blankenship, Massey Energy Company’s chairman, in bringing Hugh Caperton and his businesses to financial ruin.

    This opinion will generate a lot of discussion, particularly because the Court agreed that the plaintiffs were entitled to the verdict returned by the jury, but reversed on relatively narrow grounds. Paul J. Nyden wrote about the decision in this morning’s Charleston Gazette. 

   At this point, I will conclude this post and turn my attention to dinner, which is nearly ready.  Happy Thanksgiving to everyone. 

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    A story on the front-page of yesterday’s Wall Street Journal focuses attention on an important legal issue, but one that I suspect a lot of people may not appreciate: a health plan’s right of subrogation.  The article, entitled "Accident Victims Face Grab for Legal Winnings" discusses an employer health plan’s successful effort to obtain reimbursement for health care costs paid on behalf of an employee who was severely injured in a motor vehicle accident. 

    The employee, Deborah Shank, who was injured seven years ago, obtained a $700,000 settlement from the trucking company whose tractor trailer crashed into her car.  After attorney’s fees and expenses were deducted, she was left with $417,000, which was put in a special needs trust for her future care.  But her employer, Wal-Mart, Inc., pursued a lawsuit against her, seeking reimbursement for nearly $470,000 in medical expenses that its health plan had paid on her behalf. 

    A district court ruled in Wal-Mart’s favor, and that ruling was affirmed by the Eighth Circuit Court of Appeals in August.  Administrative Committee of Wal-Mart Stores, Inc. Associates' Health and Welfare Plan v. Shank, 500 F.3d 834 (8th Cir. 2007).  Mrs. Shank’s motion for en banc reconsideration of the decision was rejected last week, which leaves an appeal to the Supreme Court of the United States as her last hope.

    Roy Harmon, in his Health Plan Law blog, described the article as “provocative,” and he’s right.  Having Wal-Mart as the employer in this situation invites more scrutiny of its actions than another employer might receive. But I have found that entities, like corporations, that receive more attention for their actions than others receive often deserve the extra attention, and this is one of those situations.

    Assuming that a health plan, like Wal-Mart’s, has language that entitles it to reimbursement of expenses paid on behalf of plan participants who receive compensation from an accident settlement or other third-party, the plan should be reimbursed.  But as Roy also pointed out, most plan administrators try to work out settlements of claims such as Mrs. Shank’s for a couple of reasons, including the legal expenses that the plan might incur in pursuing a recovery and a plan’s natural reluctance to sue its own employee to recover the costs.  Not surprisingly, neither of these factors was of concern to Wal-Mart.  In fact, Mrs. Shank’s lawyer said he approached Wal-Mart about settling its claim, “but was told the health plan wanted to proceed with the lawsuit.”

    There is one point mentioned in the article that I would like to have known more about.  The author, Vanessa Furhmans, writes that after Mrs. Shank’s lawyer informed Wal-Mart that the settlement funds had been placed in a special needs trust, Wal-Mart waited three years to sue Mrs. Shank for the money.  Why did Wal-Mart wait so long?  After three years, isn’t Mrs. Shank entitled to conclude that Wal-Mart isn’t going to pursue any right of subrogation against her?

    The Healthcare Neutral ADR Blog, written by Richard J. Webb, also has a post about the article, which highlights the need to “get all players at the table,” i.e., involve everyone who has or may have an interest in the settlement at a point when that involvement is meaningful.  If you represent plaintiffs or defendants in personal injury litigation, sooner or later, you will confront a situation like this.  The facts may not be outrageous as Mrs. Shank’s, but the scenario will be the same or very similar, and you need to be prepared.  Likewise, if you do work for health plans, you need to be prepared to deal with situations like this one.  Hopefully, an outcome like Deborah Shank’s will be the exception rather than the rule.   

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    An article in the November issue of Litigation News, published by the American Bar Association Section of Litigation, caught my eye, for obvious reasons.  The article, written by Ruth E. Piller and entitled “Bigger Isn’t Always Better When It Comes to Outside Counsel,” reports that increasingly, corporate clients are relying on small firms and solo practitioners for representation. 

    According to the article, small firms offer flexibility on billing arrangements and an opportunity for a corporate client to be “big fish in a small pond,” which may not be the case when the client is being represented by a large firm, which has neither the ability nor the desire to be flexible about billing, and, because of its roster of clients, can’t give the client the attention that the client may want or expect.  Plus, ever-improving technology means that small firms can enjoy advantages that previously were available only to larger firms.

    Although large firms are in no danger of being replaced by small ones, they no longer represent the only option for corporations seeking representation.  Consequently, as I've written previously, large firms compete not only with each other for business, but with much smaller firms, which is an unfamiliar position for many of them.  Legal marketing guru Larry Bodine has written extensively about the changing climate for legal services, including this post about how to get business from corporate clients.

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    On Wednesday, Charleston Gazette reporter Paul J. Nyden wrote that the first medical malpractice trial against Dr. John King would start on November 27 in Putnam County, despite a request by Putnam General Hospital to change the venue.

    At a hearing on Tuesday, Circuit Judge O. C. Spaulding declined to move the trial, but acknowledged that continued publicity could require a change of venue.  PGH also urged the court to reverse the determination that punitive damages could be awarded against the hospital, as a result of the verdict earlier this year when PGH and its parent, HCA, were found to have negligently hired and credentialed King as an orthopedic surgeon.  Spaulding upheld the verdict, which means that punitive damages are available to the plaintiffs in the 122 pending cases. 

    Then, another article by Nyden in yesterday’s Saturday Gazette-Mail described a development that could affect the cases, at least temporarily.  At a previously scheduled pre-trial hearing on Friday, Judge Spaulding reported that King’s lawyer had contacted him and indicated that King intends to file for personal bankruptcy, perhaps as early as this coming week.  As a result, Spaulding postponed the trial scheduled for November 27 until December 3.

    Federal bankruptcy law would give King an automatic stay of at least 90 days, and perhaps considerably longer.  The plaintiffs’ lawyers could move to lift the stay in order for the cases to proceed, but I think the bankruptcy court would likely keep the stay in effect.

    I will post King’s bankruptcy petition as soon as it is available.  At this point, it’s impossible to know his financial condition and whether his decision to file for bankruptcy is simply intended to delay the trial or is motivated by some other consideration.  I doubt that the plaintiffs have ever expected to collect anything from King personally.  With 122 cases, many of which present absolutely egregious instances of malpractice, any meaningful recovery for the plaintiffs would have to come from the other defendants, including PGH and HCA. 

    Spaulding has scheduled another pre-trial hearing for November 28 and will begin jury selection on November 29, unless the proceedings are stayed by King’s bankruptcy.  More trials are scheduled to start in January 2008, which would also be affected by any filing.

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    It didn’t take the Supreme Court of Appeals long to issue its ruling in Wetzel v. Employers Service Corporation of West Virginia, 2007 WL 3312679 (W.Va.), which was argued on October 10, and which I discussed on October 23.

    The issue was whether the claimant's widow could hold the workers' compensation claims administrator for her husband's employer liable for its conduct in allegedly causing or hastening his death from an occupational disease.  Mary Wetzel claimed that Employers Service Corporation of West Virginia (ESC), the claims administrator for Chemical Leaman Tank Lines, was not Chemical Leaman's agent and therefore not entitled to the statutory immunity from civil liability that traditionally applied to workers' compensation employers.  Alternatively, she argued that if ESC was Chemical Leaman's agent, then ESC was liable under an intentional tort theory.  She also argued that she could assert a claim for unfair trade practices against ESC because it was in the business of insurance in processing and paying workers' compensation claims for Chemical Leaman.

    The Supreme Court was not persuaded by any of the plaintiff's theories.  in a per curiam opinion, the Court found that, under its prior decision interpreting the meaning of "agent," ESC, in its capacity as workers' compensation claims administrator, was Chemical Leaman's agent for workers' compensation purposes. 

    The Court also rejected the plaintiff's theory that even if ESC was Chemical Leaman's agent, ESC could be liable for its intentional refusal to pay certain medical claims.  The plaintiff had not alleged a deliberate intention claim against ESC, as provided by West Virginia Code § 23-4-2(d)(2), which is traditionally the only method of defeating workers' compensation immunity, but had urged a new cause of action for ESC's intentional refusal "to honor and timely pay workers' compensation benefits."  The Court expressed concern that recognizing the plaintiff's cause of action would interfere with an employer's right to contest an employee's claim, which had also been the Court's concern in Persinger v. Peabody Coal Co., 474 S.E.2d 887 (W.Va. 1996). 

    Finally, the Court concluded that ESC was not in the business of insurance for purposes of the plaintiff's claim under the West Virginia Unfair Trade Practices Act.  The plaintiff had conceded that ESC was not an insurer, but claimed that it was engaged in the business of insurance, which brought it within the scope of the UTPA.   In so holding, the Court affirmed its ruling in Hawkins v. Ford Motor Co., 566 S.E.2d 624 (W.Va. 2002), which had established that self-insured employers that process their own liability claims are not liable for unfair trade practice claims.  (The Court also pointed out in a footnote that in amendments to the Workers' Compensation Act in 2005, the Legislature had eliminated claims such as Mrs. Wetzel's, which alleged violations of the UTPA by a private workers' compensation carrier or third-party administrator or by its employees or agents.)
   
    Justices Joseph Albright and Larry Starcher dissented, and would have reversed the circuit court's rulings regarding ESC's immunity and its liability under the UTPA.  Their opinions accused the majority of reading the pertinent statutes on both issues too broadly, with the result that ESC improperly received immunity from liability and Mrs. Wetzel was deprived of her day in court.

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    In a ruling issued last month, the Supreme Court of Appeals of West Virginia ruled that a circuit court should have given the plaintiffs the opportunity to amend their complaint against two local hospitals in accordance with the West Virginia Medical Professional Liability Act (MPLA), rather than suffer the dismissal of their lawsuit for failure to comply with its provisions.  Blankenship v. Ethicon, Inc., 2007 WL 30344262 (W.Va.).

    In 2003, the plaintiffs filed suit against several defendants, including Charleston Area Medical Center and Herbert J. Thomas Memorial Hospital, resulting from the implantation of contaminated sutures.  The plaintiffs asserted several causes of action against the defendants, including product liability claims for negligence, strict liability, and breach of express and implied warranties, violations of the West Virginia Consumer Credit and Protection Act, and the intentional infliction of emotional distress.  The plaintiffs sought compensatory and punitive damages and equitable relief in the form of an investigation by the hospitals to investigate and determine “what patients were implanted with the Vicryl sutures and to then inform the patients so identified of the defective condition of those sutures.”

    The hospitals alleged that any claims against them must be pled according to the MPLA, which required the plaintiffs to obtain a certificate of merit for their claims and to provide the hospitals with pre-suit notice of the action. The hospitals moved for summary judgment on the grounds the plaintiffs’ claims were barred by their failure to comply with the MPLA.

Continue Reading...

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    This is an update to my post from September about Julie Roehm and her wrongful termination lawsuit against Wal-Mart.  As of that point, after federal district judge in Michigan had remanded the case to state court, a Michigan state court judge granted Wal-Mart's motion to dismiss on the grounds that Arkansas was the proper venue for the lawsuit.  Wal-Mart had also asserted a counterclaim against Roehm for breach of her fiduciary duty.

     According to today's Wall Street Journal, Roehm and Wal-Mart have agreed not to pursue their actions against each other, and Roehm has acknowledged that she made inaccurate statements about the business relationship between Wal-Mart and its CEO, Lee Scott, and Minnesota businessman Irwin Jacobs.  Those statements, in which Roehm accused Jacobs of selling Scott merchandise, such as yachts and a large diamond, at preferential prices, prompted Jacobs to sue Roehm for defamation in Arkansas state court.  Jacobs will announce today that he will drop his lawsuit against Roehm.

     The Journal says that Roehm decided not to pursue the lawsuit because it was "financially draining," and notes that she was "influenced by by a 'recent exchange of information between her lawyers and those for Wal-Mart and Irwin Jacobs'" regarding the allegations that she made about their relationship.

    It looks like Roehm and her lawyers figured out she wasn't going to be able to beat Wal-Mart, particularly in Arkansas, and was going to have to spend a lot of money in the process.  In addition, because there was apparently considerable merit to Irwin Jacobs' defamation action, Roehm could have faced the prospect of not recovering anything from Wal-Mart, but having to compensate Jacobs (and maybe Wal-Mart) for their claims.

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   The Alabama Appellate Watch blog, which is published by Lightfoot Franklin & White, LLC, reports that earlier this week, the Supreme Court of Alabama reversed a $3.5 billion punitive verdict rendered against ExxonMobil Corporation in 2003.  Lightfoot Franklin was among the counsel for ExxonMobil in the appeal.  There is a separate post that provides news coverage of the decision. 

    The case was first tried in 1999 and resulted in a compensatory damages verdict of $87 million and a punitive damages verdict of $3.42 billion in favor of the plaintiff, the Alabama Department of Conservation and Natural Resources.  The Supreme Court reversed on the grounds that the trial court had improperly admitted a confidential letter from Exxon's in-house counsel and ordered a new trial. 

    In the retrial in 2003, which was the subject of this appeal, the jury awarded punitive damages of $11.8 billion and compensatory damages of $102.8 million for the plaintiff.  The State claimed that Exxon deliberately underpaid royalties that were due the State from natural gas wells that Exxon drilled in State-owned waters along the coast.  The trial court reduced the punitive award by $8.5 billion based on an impermissibly high ratio of compensatory to punitive damages.

     The Supreme Court held that the plaintiff had not proven that Exxon committed fraud and reversed the entire punitive damage award, which had been based on the jury's finding that Exxon defrauded the State.  The Court affirmed the award of compensatory damages for breach of contract, but reduced that verdict from $63.7 million to $51.9 million, and remanded the matter to the trial court with directions to award compensatory damages and interest consistent with the opinion, which, according to an attorney for the State, would amount to approximately $80 million.

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    Over the summer, I wrote about the legal troubles of Shirley A. Cunningham, Jr., William J. Gallion, and Melbourne Mills, Jr., the three Fen-Phen lawyers who are still in a Kentucky jail, following United States District Judge William Bertelsman’s decision to incarcerate them pending their trial on wire fraud charges in January 2008.

    As I explained in June, Gallion and Cunningham purchased a thoroughbred named Curlin for $57,000 in 2005, then sold 80% of their interest in February for $3.5 million.  Curlin has had a spectacular year as a three year old, winning the Preakness, running second in the Belmont, and third in the Kentucky Derby. Then, last Saturday, Curlin won the $5 million Breeders' Cup Classic, which entitles him to 54% of the purse, or $2.7 million. 

    In my post, I had pointed out that there would likely be litigation about Curlin's ownership, as Angela Ford, the lawyer representing most of the plaintiffs whom Gallion and Cunningham are accused of defrauding, alleged that Gallion and Cunningham bought the horse with money improperly withheld from her clients, which would make her clients the horse's owners and would void the sale of the 80% interest.

    The Daily Racing Form reports that last Thursday, Boone County (Kentucky) Circuit Court Judge William Wehr gave the 418 plaintiffs control over Tandy LLC, a corporation owned by Gallion and Cunningham, which owns Midnight Cry Stable, which in turn owns 20% of Curlin.   According to the article, Angela Ford says her clients want to sell their interest in Curlin, as do his other owners.   Curlin is likely to be named the Horse of the Year, which will increase his value even more.

    What is not clear (at least from the DRF article) is how Judge Wehr could make this determination now, when Cunningham and Gallion (as Curlin's part owners) have not gone to trial yet on the federal fraud charges, and thus have not been found guilty of anything.  Typically, when criminal and civil actions arise from the same conduct, the civil action has to be stayed until the criminal proceeding is resolved.  An acquittal in the criminal case is not necessarily a bar to a successful civil action (ask O.J. Simpson), but the criminal charges, which have a higher standard of proof, etc., take precedence. 

    This ruling also puts Curlin's ownership in limbo, because I don't know who would buy any interest at this point, until the issue of the identity of the true owners has been resolved finally.  Having 418 co-owners of a 20% interest in a race horse is a recipe for disaster.

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    Wal-Mart is known for its willingness to use its buying power and market share as leverage when it negotiates.  And now apparently, Wal-Mart is extending its approach to its relationships with outside counsel.

    As reported in The Wall Street Journal Law Blog today, Miguel R. Rivera, Jr., Wal-Mart's associate general counsel for outside counsel management, issued a memo yesterday to "relationship partners" in Wal-Mart's outside counsel network, in which he announced that Wal-Mart was declaring a moratorium on across-the-board rate increases by its outside counsel, due to its belief that those rate increases are being driven by the "steady, nationwide increases in junior associate salaries."  Of course, in the memo's preceding paragraph, Rivera had asserted that, "[t]he salaries that law firms choose to pay their junior associates are none of our concern," which seems to be inconsistent with linking the associates' salaries to the need to freeze rates.

    All is not lost for Wal-Mart's outside counsel, however.  Although the moratorium will continue "until further notice," Wal-Mart will consider "reasonable, individual requests for rate increases for those attorneys in your firm who are performing at an exceptional level and whose experience and knowledge is adding substantial value toward meeting Wal-Mart's legal objectives."  Those requests must be submitted to Rivera  on or before December 15.

    But I think the most telling part of the memo is at the end.  Remember, Rivera stated in the memo's second paragraph that associates' salaries are none of Wal-Mart's concern.  In the memo's last couple of paragraphs, Rivera asks outside counsel to provide information for their  associates, from the class of 2004 through the class of 2007, who have worked on Wal-Mart matters, and then for the associates in each class, their names, their locations, the Wal-Mart matters they worked on, their billing rates, and the number of hours they billed for each year.  This information is due in spreadsheet format by November 30.  

    For any firm that objects to providing the information, Rivera  wants, by November 12, the specific reasons for the objection.  And if a firm needs more time?   Also by November 12, Rivera wants to know the steps the firm is taking "to gather and provided the requested information in a timely fashion as well as a commitment to provide the information on a date certain."
   
    Should Wal-Mart (or any client) treat legal services the same as any other commodity, such as appliances or tires?  I would like to think the nature of the attorney-client relationship is inherently different than Wal-Mart's relationship with any one of a thousand vendors, but maybe it's not.  In any event, I would view the memo as being less heavy-handed if it had not included the seemingly gratuitous language about associates' salaries being none of Wal-Mart's concern, but then imposing the rate freeze precisely because of the effect of increasing associates' salaries.

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