The Law Office of Kurt H King

May 8, 2012

Elements Of An Unfair Competition Case

Filed under: Litigation — kurthking @ 4:30 pm
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What can you do when one of your own starts up a company doing the same thing as yours and mimics your advertising and marketing practices?  Well, one thing you can do is sue them in state court in Missouri for Unfair Competition. 

But what do you have to prove?  There is currently no MAI jury instruction listing the required elements of proof–not even one close enough to modify.  Thankfully, a non-MAI verdict director was recently approved by the Eastern District of the Missouri Court of Appeals in American Equity Mortgage v. Vinson Mortgage Services, ED97103 (filed April 24, 2012). 

That case arose when an ex-husband started up Vinson Mortgage Services (VM) and basically copied the radio commercials and other advertising  of his former wife’s company–the plaintiff American Equity Mortgage.   VM’s deceptive marketing apparently caused customers to call American Equity asking for VM and Mr. Vinton (the ex-husband).  Copy by VM went beyond the use of certain phrases and slogans; rather, VM’s advertisements were “virtually identical.”

On these circumstances, the court of appeals affirmed the $300,000 jury verdict for plaintiff American Equity, rejecting VM’s argument that the key jury instruction–the verdit director listing the elements the jury must find to decide in favor of the plaintiff–was erroneous.  Thus, the elements of such unfair competition as approved by the court are:

1.  VM engaged in conduct likely to deceive or mislead prospective cusotmers; and,

2.  Such conduct caused the mistaken belief that: (i) VM’s business was that of American Equity, or (ii) VM is American Equity or an agent, affiliate or associate of American Equity, or

     (iii) VM’s mortgage services were produced, sponsored, or approved by American Equity; and,

3.  Such conduct by VM damaged American Equity.

 

(An instruction said to follow Restatement of Unfair Competition, Section 4.)

To conclude, while unfair competition cases may arise due to wrongful acts different from those in the case discussed here, and so may require a verdict director altered from that approved here, at least the court of appeals lends us a general road map on what a proper verdict director needs to say for the trial court to safely give it to the jury.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Personal Injury, Business & General Litigation, Workers’ Compensation

Family Law–Divorce & Modification, Child Custody & Support, Paternity

Chapter 7 Bankruptcy for debtors

 

April 20, 2012

Does the ex-Spouse get the Ford Retirement?

Filed under: Divorce,Family Law,Litigation,Paternity,Uncategorized — kurthking @ 4:53 am
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Fact-set:  Ford worker dies soon after a contested Missouri divorce.  His Ford retirement benefits include money in the TESPHE savings plan and a group life insurance benefit.  During the divorce the Ford worker changed the beneficiary on the life insurance without the wife’s consent.  The beneficiary on the TESPHE never changed and the ex-spouse is still the named beneficiary.  What happens?

Like many states, Missouri law includes a statute that provides that upon divorce, the ex-spouse loses all rights as a named beneficiary of property owned by the other spouse.  See VAMS 461.051.1.  But while this law may bar the ex-spouse as beneficiary on an IRA (an example of a non-ERISA asset), a Ford worker’s retirement includes (1) the TESPHE savings plan, and/or (2) a pension plan–both of which are governed by federal law known as ERISA (Employee Retirement Income Security Act), as later modified by the REA (Retirement Equity Act).  ERISA preempts/overrides state law on matters sufficiently related to ERISA–including Missouri’s section 461.051.1.  See Egelhoff v. Egelhoff, 532 U.S. 141 (2001).

Note that the group life insurance provided by the employer is a welfare plan–not a retirement plan and thus not governed by ERISA or REA federal law.

Key questions:  (1) can the Ford worker validly change (before the divorce is final) the beneficiary on the life insurance benefit without the spouse’s consent?; and (2) is the ex-spouse entitled to the balance in the TESPHE savings plan since the ex-spouse remains the named beneficiary–even though the divorce judgment awarded all the retirement to the ex-husband/employee?

Generally, Missouri law and ERISA’s 29 U.S.C. section 1055 seems to allow change of beneficiary of LIFE INSURANCE during the marriage without the spouse’s consent.   So the Ford employee’s change of beneficiary on the employee life insurance benefit from spouse to adult son appears to be valid and lawful where the welfare plan and the underlying life insurance policy itself do not expressly prohibit.  See Sun Life Assurance Co. v. Mae Bell Benjamin, Case 1:09 CV 2452 (U.S. Dist. Ct., Northern District of Ohio, Eastern Division 2010). .

However, as to the FORD RETIREMENT, federal ERISA law governs.  DURING THE MARRIAGE, 29 U.S.C. section 1055 protects the worker’s spouse from being left high and dry form the employee changing the beneficiary on the retirement while married, mandating by law that the spouse gets at least half of the pension (the “qualified joint and survivor annuity) UNLESS (1) the spouse consents in a very specific writing that is notarized or witnessed by a plan representative; or, (2) by a Qualified Domestic Relations Order (“QDRO”) used in the case of divorce.  See subsection (c)(2)(A)  of section 1055 as to how a spouse may waive her interest in the worker’s pension plan.   And see 29 U.S.C. section 1056(d)(3) as to alienation/transfer of the spouse’s share by means of a QDRO.  Simply put, Congress crafted ERISA to grant the worker’s spouse at least half of the pension plan benefits, and to prevent the transfer or taking of the spouse’s share of the pension plan benefits without the spouse’s consent.

But what about cases where the divorce court awards the retirement to the employee, only for the employee ex-spouse to fail to change the beneficiary after the divorce?  A pair of U.S. Supreme Court cases squarely answer the question.

First, in Egelhoff v. Egelhoff, 532 U.S. 141 (2001), the high court held that pension plan administrators need only apply the language of the plan and pay the money to the last named beneficiary.  In so ruling, the Court observed that payment of pension plan benefits is a central aspect of ERISA plans and that it is unduly burdensome to saddle plan administrators with the task of figuring out the various laws that nearly all 50 states have to prevent the ex-spouse from getting the pension plan money after the divorce.  The Court focused on the need for the administrator to simply apply the pension plan’s provisions to determine the proper payee to save the time and expense of ascertaining  myriad state laws and the innumerable interpleader lawsuits that would result to protect the administrator from double liability due to paying the wrong payee.  So, with qualified pension plans, ERISA preempts state laws such as Missouri’s that attempt to cancel out the ex-spouse as the beneficiary after divorce.  Consequently, if the employee-spouse fails to change the  beneficiary after the divorce and leaves the now ex-spouse as beneficiary, the ex-spouse is entitled to employee’s pension plan monies.

Lastly, what of provisions commonly found in divorce settlement agreements which are often incorporated or quoted in the court judgments dissolving marriages–typically providing that each spouse forever waives all interests in the property awarded to the other party?  This question the Supreme Court answered in Kennedy v. Kennedy, 129 S.Ct. 865 (2009), involving a pension plan, where the Court held that the plan administrator need only follow the dictates of the plan on which the employee left the ex-spouse as beneficiary after divorce.  The plan administrator is free to IGNORE language in the divorce decree that the wife “is . . . divested of all right, title, interest, and claim in and to . . . [a]ny and all sums . . . the proceeds [from], and any other rights related to any  . . . retirement plan, pension plan, or like benefit program existing by reason of [William’s] past or present or future employment.”   Hence, the boilerplate waiver language in many divorce settlement agreements and judgments does not preclude the ex-spouse from receiving the proceeds of the pension plan on which she was left as named beneficiary after divorce.

Of note on page 15 of the Kennedy opinion is the Court’s statement that:  “ERISA forecloses any justification for enquiries into nice expressions of intent, in favor of the virtures of adhering to an uncomplicated rule: ‘simple administration, avoid[ing] double liability, and ensur[ing] that beneficiaries get what’s coming quickly, without the folderol essential under less-certain rules.'”

And on 17:  “What goes for inconsistent state law goes for a federal common law of waiver that might obsure a plan administrator’s duty to act in accordance with the documents and instruments.'”

“And this case does as well as any other in pointing out the wisdom of protecting the plan documents rule.”  (Also on page 17 of the opinion.)

In summary after considerable research of Missouri and federal common law, mind-mashing ERISA statutes, and U.S. Supreme Court opinions–the ex-spouse as cast above is the last named beneficiary on the TESPHE pension plan and as such entitled to those funds since there was no QDRO or consent divesting the ex-spouse as beneficiary.  If you are an employee with retirement or pension, make absolutely sure that you change the benficiary away from the ex-spouse unless yours is the rare case where you want the ex-spouse to remain as beneficiary.

Kurt H. King

Law Office of Kurt H. King, 20  E. Franklin, Liberty, MO 64068

816.781.6000

divorce & modification, child cusotdy and visitation, support and paternity

personal injury & workers’ compensation, bankruptcy, and probate.

April 4, 2012

Who Owns The Church Anyway?

Filed under: Litigation — kurthking @ 6:05 pm
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Does the local church own the church land and building, or does the denomination?   This question the Westen District of the Missouri Court of Appeals answered in its January 10, 2012, decision in the case styled Heartland Presbytery v. Gashland Presbyterian Church. On the facts of this case, the court of appeals held that the local Gashland Presbyterian church owned the land and church buildings, resolving this dispute arising out of Gashland’s dissassociation with the Presbyterian denomination.

In deciding the case, the court applied the “neutral principles” approach rather than the “rule of deference” to the church on religious matters.  The neutral approach holds that “there are neutral principles of law, developed for use in all property disputes, which can be applied without ‘establishing’ churches to which the property is awarded.”  (It is constitutionally taboo in this country for the government to establish a church due to the separation of church and state so fundamentally important to the founding fathers who wrote the  Constitution and  Bill of Rights.)    Applying  “neutral principles,” the court looked to: 1.  the Deed; 2. the local church’s Articles and By-Laws; 3.  the national denomination’s Constitution (although Heartland Presbytery, the local district governing body, was the actual party of denomination named in the lawsuit).  The analysis of these documents focused on whether the local church clearly expressed an intent to hold the land and building in trust for the denomination.

First–the deed clearly named the local church as owner of the property with no expression whatsoever of any intent to hold in trust for the district Presbytery or the national denomination (Presbyterian Church of the United States–“PCUSA”).  Indeed, the 1948 deed named “Gashland Community Church, Gashland, Missouri” as the sole owner.  The court notes on page 2 of 28 that with the 1948 deed, “Gashland constructed a church on the property.”  While not in the opinion, the history of that church as related to me when a member there is that the original members of Gashland built the original stone and beam sanctuary with their own hands–quarrying the stone at a local site, erecting beams, framing the roof, laying flooring, etc.  

With the deed supporting ownership by Gashland, the court then looked to the Articles of Agreement adopted by Gashland in 1948, and its amended By-Laws of 1987.  Here too the Articles pointed to ownership by Gashland free of any trust in favor of the denomination as Article VII provides that title to property acquired by Gashland “shall vest in the Gashland Community Church of Gashland, Missouri, in its corporate capacity.”   

But, part of the By-Laws of 1987 favored the denomination in providing that Gashland “recognizes that the Constitution of the Presbyterian Church (U.S.A.) is, in all of its provisions, obligatory upon it and its members.”  And, “[n]othing in these By-Laws shall nullify or contravene the provisions of the Constitution of the Presbyterian Church (U.S.A.) and they shall be construed only in conformity therewith.”  However, these By-Law provisions conflicted with the Articles of Gashland and Articles control over By-Laws, so the denomination also lost this point to Gashland.

Third, the denomination argued that, standing alone, the Property-Trust Clause that first appeared in its Book of Order in 1981 and its Constitution in 1983, established a trust over Gashland church property.  This Clause basically states that legal title to all member church property, no matter how title is actually documented, is “held in trust nevertheless for the use and benefit of the Presbyterian Church (U.S.A.).”  However, the court clipped the wings of this one-sided unilateral imposition by the denomination, finding insufficient indicia of “some effective expression of Gashland’s agreement to be bound by [the Clause].”   Thus, the denomination’s self-serving attempt to seize ownership through the Clause crashed and burned for lack of sufficient proof that Gashland acted with like intent that its property be held in trust for the denomination. 

And so the court held that Gashland owns the church land and buildings, built and paid for by its members.

Food for thought as Gashland is likely not the only local church with this set of facts.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Litigation, Personal Injury, Workers’ Compensation, Bankruptcy

Family Law including Child Custody & Support, Divorce & Modification, Paternity

March 27, 2012

Embezzler Entitled to Offset for Accounting Firm’s Failure to Catch the Embezzlement

Filed under: Litigation — kurthking @ 4:54 pm
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Interesting new Missouri case out of the Eastern Division of the Court of Appeals involving embezzlement of roughly $2.4 million–Moore Automotive Group v. Lewis, et al., Slip Op. No. ED95870 (Filed March 20, 2012).

Over 8 years, the Chief Financial Officer of the plaintiff automotive group (the “Group”) embezzles over $2.4 million to “pay her personal expenses.”  The accounting firm used by the Group fails to catch the embezzlement.  When finally caught, the CFO/employee pleads guilty in U.S. District Court.  The Group sues the employee for the $2.4 million and the court grants summary judgment for the Group against the employee, based on written motions without a trial to the court or jury.  The employee appeals, contending that it is error to grant summary judgment because there is a material fact as to how much the $2.4 million should be reduced by offsets.  The main offsets are the $1.5 million the accounting paid firm paid the Group for its mistakes in not catching the embezzlement; another $500,000 of accounting fees that the accounting firm “forgave”–wrote off; and $115k from American Express. 

All agreed that the $115k paid by American Express to the Group is an offset which reduced the $2.4 million total.  The main question addressed by the court of appeals is whether the $1.5 million paid in settlement by the accounting firm is also an offset.  Ultimately, the court of appeals ruled that “yes” the $1.5 million is an offset, and sent the case back down to the trial court without reaching the argument for further offset due to the $500k forgiveness of accounting fees.

The main rule of law applied is simple–“Under Missouri law, a plaintiff is entitled to only one satisfaction of the same wrong.”   So, the Group cannot have judgment against  the employee for $2.4 million, take the $1.5 million in settlement from that the accounting firm, ($500k accounting fee write off?), and receive $115k from American Express since all that would total $4 million for a $2.4 million loss. 

So the Group hatched Plan A–argue that the $1.5 million was for something else besides the embezzlement.  This the Group could not show.  In fact the facts pointed the opposite direction as important witnesses basically said that the reason why the accounting firm paid the $1.5 million was to settle the Group’s claim against the firm for failure to prevent or detect the embezzlement.  

Losing on that one, the Group goes to Plan B–the Collateral Source Rule precludes the embezzler from benefitting from the $1.5 million paid by a collateral source, i.e., the accounting firm.  But, the Rule is mainly to prevent the wrongdoer from benefitting from payments by insurance companies  to which the injured plaintiff typically pays insurance premiums.  Clearly a wrongdoer should not benefit from insurance for which the injured plaintiff has been paying out his/her/its own pocket.  While the Rule has been stretched a bit beyond the typical insurance scenario, the court of appeals declines to pull it so far as to cover the accounting firm’s payment of $1.5 million.

The Group loses on Plan B too.  The court of appeals simply sees the $1.5 million settlement as a contract after the loss and not as insurance premium payments.  The Rule does not apply and the result is that the $1.5 million offset applies to cut the Group’s damages to around $900k (and maybe down another $500k for the accounting fees that firm wrote off).

This may seem like a big win for the embezzler–and it is–but the accounting firm and American Express could sue her for indemnity or contribution to recover the money they had to pay the Group due to to the embezzlement.  The result may be more lawsuits  against the embezzler by the accounting firm for $1.5 million and maybe another $500k, and $115k by American Express–which may or may not happen depending on whether the embezzler is now bankrupt, litigation costs, etc.  There was also reference to sale of her assets in connection with her plea bargain on criminal charges in federal court  so there may be some restitution required there that might conceivably put some money back in the pockets of the accounting firm and American Express.

Of note for attorneys is the court of appeals’ indication that a claim for offset should be pled as an affirmative defense or the offset may be lost.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

Civil & Business Litigation, Bankruptcy

Personal Injury & Workers’ Compensation

Family Law–Child Custody & Support, Paternity, Dissolution & Modification

www.kurthking.com

December 28, 2011

Missouri Workers’ Compensation Law on Claims by Health Care Providers

Filed under: Litigation,Missouri Workers Compensation — kurthking @ 3:52 pm
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Under Missouri Workers’ Compensation law the employer or its work comp insurer are supposed to pay for medical treatment necessary to care for the employee’s injury.  However, when the employee’s work comp claim settles for a final lump sum, part of the settlement paid to the employee may include an amount for any unpaid medical expenses owed to health care providers who have not yet been paid.  Then the burden shifts to the employee to pay any outstanding medical bills.  The question is how much does the employee have to pay the health care provider–the full amount of the bill or the much smaller percentage (often 20% or less) that an insurance company like Blue Cross Blue Shield would have to pay.

A few years ago, Missouri law changed section 287.140 of the Revised Missouri Statutes to clearly state in subsection 3 that no health care provider may charge the employee more than the amount that would have been due from a health insurance company or if the patient was a private pay.  Thus, the employee in these situations need pay no more than the percentage that the insurance carrier would have paid, saving perhaps 80% or more off the full amount that a health care provider may bill without knowing of the law or in hopes of obtaining full payment. 

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Missouri Workers’ Compensation Law, Personal Injury, Lender Liability Litigation, Divorce & Modification, Child Custody & Support, Family Law, Bankruptcy

Chapter 7 Bankruptcy & Walking Away From A Home Loan

Filed under: Bankruptcy,Litigation — kurthking @ 10:22 am
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Folks who have lost their job or otherwise fallen on hard times sometimes lack the money to make their home loan payments.   Too, the value of the residence may have fallen, leaving the home owner under water with a loan balance that far exceeds the value of the property.  In situations like these, the owner may consider walking away from the property and defaulting on the loan.

Does the bank/lender sell the home at the foreclosure sale and mark the loan Paid In Full so the borrower can move on and start afresh?  Not hardly. 

Typically, there is a balance due from the borrowers after the sale that is called a deficiency.  The lender can sue the borrowers and garnish their wages or otherwise try to collect the deficiency.  At the least, the default shows up on a credit report and makes it difficult or impossible for the borrowers to get loans in the future so long as the deficiency remains on their record.

Some folks qualify to file bankruptcy, often under Chapter 7 to wipe out debts and start over or under Chapter 13 where a payment plan is ordered requiring the debtor/borrower to pay part of the debts over several years.

For those borrowers who cannot qualify for relief in bankruptcy court, walking away from a home loan may be a nightmare with no end in sight.  Don’t make the mistake of going that route without seeing if there are any other options.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Bankruptcy, Litigation, Personal Injury, Missouri Workers’ Compensation, Family Law

 

Late Payment of Compensation Checks–Missouri Workers’ Compensation Claims

Filed under: Litigation,Missouri Workers Compensation — kurthking @ 9:22 am
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In some cases, a work comp insurance company drags its feet or refuses to pay the injured employee the “weekly” compensation checks for Temporay Disability due the employee while recovering from or receiving medical treatment for the injury.   This is extremely frustrating for the injured employee now trying to make ends meet on work comp which pays no more than 2/3 of the worker’s wages and even that amount is capped so that employees making good money do not receive the full 2/3 amount.

Missouri work comp law is not a big help.  Section 287.160 merely provides in subsection 3 that the payments are to be made as frequently as the employee was paid at the time of injury, but at least bi-weekly.   Unfortunately, the penalty for late payment is only 10% simple annual interest AFTER THE PAYMENT IS MORE THAN 30 DAYS LATE.

Too, in rare cases an unreasonable refusal to pay the compensation due results in an award of attorneys fees/costs to the employee.  Don’t hold your breath expecting one of these attorney fees awards.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Missouri Workers’  Compensation, Personal Injury Law, Bankruptcy, Child Custody & Support, Divorce & Modification, Family Law

December 22, 2011

Spinal Cement Surgery in Missouri Personal Injury and Workers’ Compensation Cases

Filed under: Litigation,Missouri Personal Injury Law,Missouri Workers Compensation — kurthking @ 5:13 pm
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Received a call last week from a guy with a Missouri Workers’ Compensation claim who went under the knife to have a vertebroplasty where cement is injected into a fracture to hold it together until the bone rebuilds.   The work comp insurance carrier already offered this person a settlement and the call was to find out if the offer was in the ball park, which it was not.  This person decided to try to renegotiate a higher settlement on his own after talking to me about number in hopes of having a decent net settlement without having to pay the 25% contingency fee to me and at least a $1,000 for another doctor to examine him and give the higher rating the injury deserved.  I don’t yet know how he fared on his negotiations.

After this phone call, I looked on-line at spinal surgery using cement and found that there are significant risks associated with this cement and allegations of improper and unapproved testing which may have resulted in patient deaths.  One risk is said to be that if the cement gets into the blood stream and reaches the heart, large drops in blood pressure occur.  Another concern is reported as that using cement to strengthen one fractured vertebrae could cause more fractures in weaker bones.  Maybe most strikingly, reports state that this cement surgery is no better than not having the surgery at all. 

All this raised the concern about what happens to the cement over time.  Is it absorbed into the body and how does that happen without it mixing with spinal fluid or the bloodstream which will eventually pass it though the heart?  And what damage results to the heart and its delicate valves due to the passage of rough foreign matter like cement?  Did the surgeon fully discuss all these risks and dangers with the patient as well as let the patient know of the studies that are said to indicate that the cement surgery may be no better than no surgery at all?   If not, the doctor may not have obtained the patient’s informed consent as required by law.

All in all, there seems to be considerable food for thought for anyone looking at cement surgery or such health problems afterwards.

Kurt H. King

Law Office of Kurt H. King, 20 E. Franklin, Liberty, Clay County, Missouri 64068

816.781.6000

www.kurthking.com

Personal Inury, Missouri Workers’ Compensation, Family Law, Child Custody & Support, Divorce & Modification, Bankruptcy

January 5, 2011

Costs–Hip Replacement

Filed under: Litigation,Missouri Personal Injury Law — kurthking @ 8:19 pm
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Here are hospital and surgeon costs for hip replacement after injury in motor vehicle accident in this Kansas City, Missouri area:

1. hospital $60,124
2. surgeon $4,532 (plus $2000 if use assistant)

Kurt H. King
Law Office of Kurt H. King
816.781.6000
20 E. Franklin
Liberty, Clay County, Missouri 64068
http://www.kurthking.com

Bankruptcy, Child Custody and Support, Divorce and Modification, Family Law
Personal Injury, Workers’ Compensation

Slip & Fall case out of Clay County, Missouri

Filed under: Litigation,Missouri Personal Injury Law — kurthking @ 5:10 pm
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Here in Clay County, Missouri, a tenant slip and fall case against the landlord went up to the appeals court which outlined Missouri law on point. The appellate opinion is at 935 S.W.2d 649 out of the Western District of the Missouri Court of Appeals, and titled Uptergrove v. Housing Authority of the City of Lawson, Mo.

This case makes a good statement of Missouri law existing on this area of personal injury law. The general rule in Missouri is that the landlord has no duty to tenant to remove snow and ice from the common areas of the apartment complex, unless he takes on that duty: (1) by agreement with the tenant, or (2) assumed the duty by making it a practice to remove the snow and ice.

Some tenants who are injured by slip and fall on a common walkway or parking lot look to their lease (usually provided by the landlord for the landlord’s benefit) and see that it puts no duty to remove on the landlord, or states that the tenant waives/releases his/her claims against the landlord for non-removal of snow and ice. Don’t make the mistake of thinking that is the end of your claim. There is more to it than that and the tenant may still have a case to recover for personal injury, loss of wages, property damage, etc. Have it checked out.

Kurt H. King
Law Office of Kurt H. King
816.781.6000
20 E. Franklin
Liberty, Clay County, Missouri 64068
http://www.kurthking.com

Bankruptcy, Child Custody and Support, Divorce and Modification, Family Law
Personal Injury, Workers’ Compensation

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