HomeMy WebLinkAbout2002-4922 Civil
RITE AID CORPORATION, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : CIVIL ACTION - LAW
: 02-4922 CIVIL
FRANKLIN BROWN, :
Defendant :
IN RE: MOTION FOR PARTIAL SUMMARY JUDGMENT OF RITE AID CORPORATION
BEFORE HESS, P.J., OLER AND GUIDO, J.J.
OPINION AND ORDER
The question before the Court is whether the plaintiff, Rite Aid Corporation, is entitled to
partial summary judgment in its favor as to liability on Counts I through VI of its amended
complaint. Rite Aid’s amended complaint, and accompanying memorandum in support thereof,
begins with a statement of substantive allegations and facts.
Franklin C. Brown formerly served as Vice Chairman of the Board of Directors and
Chief Legal Office of Rite Aid. On June 21, 2002, a grand jury sitting in the Middle District of
Pennsylvania returned an indictment against Martin L. Grass, former Chief Executive Officer of
Rite Aid, Brown, Franklin M. Bergonzi, former Chief Financial officer of Rite Aid, and others.
The indictment (attached to plaintiff’s First Amended Complaint as “Exhibit A”) charged Brown
and his co-defendants with participating in two broad criminal conspiracies: a conspiracy to
defraud Rite Aid, its Board of Directors, shareholders, investors and vendors; and a conspiracy to
obstruct justice. The charges against Brown and the others included, among other things,
creating and submitting to the company fraudulently back-dated and unauthorized employment
agreements purporting to grant certain employees, including Brown, millions of dollars of
benefits; with having caused the company to guarantee loans to corporate executives without
authority from the company’s Board of Directors; with having pledged company assets without
NO. 02-4922 CIVIL
authority from the company’s Board of Directors; with having used company assets for
unauthorized private transactions; with having falsely certified Board authorization for such
actions where none had been granted; and with otherwise having defrauded Rite Aid and its
Board of Directors.
Brown’s co-conspirators pled guilty to various counts of the indictment. Brown initially
agreed to plead guilty to certain charges but reneged on the counts of the indictment, including
counts accusing him of having falsified Rite Aid’s financial statements, having conspired to
obstruct government agency and grand jury proceedings relating to investigations of the criminal
activities regarding Rite Aid, and having suborned perjury to the grand jury regarding these
matters. Brown was ultimately convicted of acts such as having defrauded Rite Aid by
fabricating and back-dating letters purporting to obligate Rite Aid to pay select officers,
including Brown, millions of dollars of unauthorized benefits upon the termination of their
employment with Rite Aid. Brown was sentenced to ten years in prison for these crimes and is
currently serving that term of incarceration.
Specifically, Brown was convicted by a jury of ten counts of the indictment, including the
most serious charges: Count 1, conspiracy to defraud Rite Aid and its Board of Directors,
shareholders, investors and vendors, among others in violation of 18 U.S.C. § 371; Count 10,
filing a false SEC Form 10K for Rite Aid’s 1999 fiscal year statement, in violation of 18 U.S.C.
§§ 1001(a)(3) and (2); count 12, filing a false 1997 Proxy Statement with the SEC, in violation
of 18 U.S.C. §§ 1001(a)(1) and (2); Count 13, filing a false 1998 Proxy Statement with the SEC,
in violation of 18 U.S.C. §§ 1001(a)(1) and (2); count 14, filing a false SEC Form 8K on
February 9, 1999, in violation of 18 U.S.C. §§ 1001(a)(1) and (2); Count 15, filing a false 1999
Proxy Statement with the SEC, in violation of 18 U.S.C. §§ 1001(a)(1) and (2); Count 33,
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conspiracy to obstruct justice, in violation of 18 U.S.C. § 371; Count 34, obstruction of grand
jury proceedings, in violation of 18 U.S.C. § 1503; Count 35, obstruction of government agency
proceedings, in violation of 18 U.S.C. § 1505; and Count 36, witness tampering, in violation of
18 U.S.C. §§ 1512(b)(1) and (2).
In addition to convicting Brown of the conspiracy charges, the jury also completed a
verdict sheet. It found that Brown committed the following overt acts in furtherance of the
conspiracy:
1. Prepared a back-dated letter purported to be
from a member of the Board’s Compensation
Committee to Grass, doubling Grass’s bonus
payment under one of the company’s incentive
plans.
2. Participating in a fraudulent rebate program
with two pharmaceutical companies, Bristol Myers
Squib and Zeneca, to help conceal Rite Aid’s
increasingly dire financial condition.
3. Falsifying documents that were filed with the
SEC.
4. Creating a fraudulent employment agreement
for Bergonzi, which was subsequently presented to
the company to be honored.
5. Creating fraudulent severance letters for Sorkin,
Noonan and another Rite Aid employee, which
were subsequently presented to the company to be
honored.
6. Submitting his own fraudulently created
severance letter to the Board.
7. Obstructing the investigations of the above-
described wrongdoing conduct by Rite Aid and the
United States Government.
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Ex. D, Verdict Form, pp. 1-4, Appendix of Exhibits in Support of the Renewed Motion of Rite
Aid Corporation for Partial Summary Judgment as to Liability. (Hereinafter “Appendix of
Exhibits”).
In imposing sentence, Federal District Judge Sylvia Rambo found that Brown was a
leader and organizer of the fraud conspiracy, obstructed the investigations of the grand jury and
the SEC, and abused his position of trust as an officer and director of Rite Aid. See U.S. v.
Brown, No. 1:02-CR-00146-2 (M.D. Pa. August 16, 2004), Memorandum Denying Defendant’s
Objections to Pre-Sentence Investigation Report, slip op. at 1, 10-13 (Ex. N, Memorandum,
Appendix of Exhibits).
The District Court also rejected Brown’s argument that he should not be held responsible
for causing a loss to Rite Aid by participating in the scheme to execute back-dated severance
letters for himself and his co-conspirators. See U.S. v. Brown, No. 1:02-CR-00146-2 at 12-13
for the portion of Judge Rambo’s opinion rejecting Brown’s argument that he should not be held
responsible for causing a loss to Rite Aid.
Pursuant to Rite Aid’s Certificate of Incorporation, the company advanced Brown costs
and expenses he claimed to have incurred in connection with his defense of the criminal charges
against him, subject to Brown’s written undertaking to repay such advances in the event it were
determined that Brown was not entitled to indemnification.
Rite Aid claims that under the doctrine of collateral estoppel, the criminal convictions
entered against Brown as a result of the jury verdict against him clearly indicate that he is not
entitled to indemnification and operate as a matter of law to preclude Brown from relitigating the
issues determined in his criminal trial. Rite Aid originally moved for partial summary judgment
as to liability on October 16, 2009; however, this Court did not have the complete record of
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Brown’s criminal trial and denied Rite Aid’s motion stating “the current state of the record does
not allow for entry of summary judgment.” On April 17, 2009, Rite Aid supplemented the
record with the transcript of the criminal trial and the exhibits admitted into evidence at that trial.
The record of the criminal trial may be found at pages 761-3765 of the Cumberland County
laserfiche Weblink (http://records.ccpa.net/weblink_public/dockview.aspx?id=10358@dbid=8).
Rite Aid’s amended complaint, filed July 7, 2004, contains 8 counts. In them, Rite Aid
seeks to recover losses it has sustained as a result of Brown’s wrongful conduct. Count I is a
claim of breach of fiduciary duty. Count II is a claim of aiding and abetting breach of fiduciary
duty. County III is a claim of fraud. Count IV is a claim of conspiracy. Count V is a claim for
breach of contract – obligations as an officer and director. Count VI is a claim for breach of
contract – deferred compensation agreement. Count VII is a claim for breach of contract –
advancement repayment undertaking, where Rite Aid seeks to recover costs of defense it
advanced to Brown under the company’s Restated Certificate of Incorporation. Count VIII is a
claim for a declaratory judgment. Rite Aid seeks partial summary judgment as to liability for
Counts I-VI of its amended complaint.
Under Rule 1035 of the Pennsylvania Rules of Civil Procedure, the court may grant
summary judgment after the relevant pleadings are closed and “whenever there is no genuine
issue of any material fact as to a necessary element of the cause of action or defense which could
be established by any additional discovery or expert report.” Pa.R.Civ.P. 1035.2(1). Summary
judgment shall be granted whenever “the material facts are undisputed,” or the facts are
insufficient “to make out a prima facie cause of action or defense.” McCarthy v. Dan Lepore &
Sons Co. Inc., 724 A.2d 938, 940 (Pa.Super. 1998); Pa. R. Civ. P. 1035.2(1). Rite Aid asserts
that the relevant pleadings are closed and the claims on which it moves for summary judgment
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do not require discovery or expert reports. Furthermore, it claims that there is no need for trial
on the issue of Brown’s liability to Rite Aid on Counts I through VI in the case because all of the
facts necessary to establish Brown’s liability to Rite Aid for each of the claims on which it seeks
summary judgment are established by his criminal convictions and the record of Brown’s
criminal trial which has been provided to the court.
Rite Aid asserts that the doctrine of collateral estoppel precludes Brown from relitigating,
in this case, issues that were decided in his criminal case, citing the following in support of this
proposition: Shaffer v. Smith, 543 Pa. 526, 530, 673 A.2d 872, 875 (1996); Hurtt v. Stirone, 416
Pa. 493, 498, 206 A.2d 624, 627 (1965); Columbia Med. Group, Inc. v. Herring & Roll, P.C.,
2003 Pa. Super. 272, ¶ 24, 829 A.2d 1184, 1193 (2003); In re Estate of Reinert, 367 Pa. Super.
147, 153, 532 A.2d 832, 835 (1987). These cases note that “[i]t is well established that a
criminal conviction collaterally estops a defendant from denying his acts in a subsequent civil
trial.” Shaffer v. Smith, 543 Pa. 526, 529 (Pa. 1996). Furthermore, the collateral estoppel effect
of a criminal conviction is not negated or diminished by the pendency of an appeal. See
Columbia Med. Group, Inc., 829 A.2d at 1193 (following Shaffer, 673 A.2d at 875 (“For
purposes of finality, we believe that holding a criminal conviction in abeyance until appellate
review is completed would result in hardship to the party seeking to invoke collateral estoppel....
Accordingly, we hold that once a criminal defendant has been convicted and sentenced, a
plaintiff in a civil proceeding may invoke collateral estoppel to preclude the defendant from
denying his criminal acts.”)). Therefore, Rite Aid asserts, and we agree, that Brown is estopped
from contesting his guilt of the crimes for which he was convicted and the facts established by
the jury’s findings of guilt on each conviction.
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Count I is a claim for breach of fiduciary duty. In order to state a claim for breach of
fiduciary duty, the plaintiff must demonstrate: 1) that the defendant negligently or intentionally
failed to act in good faith and solely for the benefit of the plaintiff in all matters for which he or
she was employed; 2) that the plaintiff suffered injury; and 3) that the agent’s failure to act
solely for the plaintiff’s benefit was a real factor in bringing about plaintiff’s injuries. Schutter v.
Herskowitz, 2008 U.S. Dist. LEXIS 7995, *16-17 (E.D. Pa. 2008) (citing McDermott v. Party
Corp., 11 F. Supp. 2d 612, 626 (E.D. Pa. 1998) and Dinger v. Allfirst Fin., Inc., 82 Fed. Appx.
rd
261 (3 Cir. 2008)). Rite Aid correctly asserts that as an officer and director of the company,
Brown owed that company a fiduciary duty of undivided loyalty. Every director and officer of a
corporation stands in a fiduciary relationship with the corporation. See 15 Pa.C.S.A. §
1712(a)(2004). Section 1712(a) provides in pertinent part:
A director of a business corporation shall stand in a
fiduciary relation to the corporation and shall
perform his duties as a director . . .in good faith, in
a manner he reasonably believes to be in the best
interests of the corporation and with such care,
including reasonably inquiry, skill and diligence,
as a person of ordinary prudence would use under
similar circumstances.
15 Pa.C.S.A. § 1712(a). Furthermore, Section 1712(b) provides that a “director shall not be
considered to be acting in good faith if he has knowledge concerning the matter in question that
would cause his reliance to be unwarranted.” 15 Pa.C.S.A. § 1712(b).
Rite Aid also correctly quotes the Supreme Court of Delaware in stating that the duty of
loyalty “embodies not only an affirmative duty to protect the interests of the corporation, but also
an obligation to refrain from conduct which would injure the corporation and its stockholders or
deprive them of profit or advantage. In short, directors must eschew any conflict between duty
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and self-interest.” Ivanhoe Partners v. Newmont Mining Corp., 535 A.2d 1334, 1345 (Del.
1987).
The duty of loyalty. . . requires that corporate
directors devote themselves to corporate affairs
with a view to promote the common interests and
not only their own, and they cannot directly or
indirectly utilize their position to obtain any
personal profit or advantage other than that
enjoyed by their fellow shareholders.
Anchel v. Shea, 762 A.2d 346, 357 (Pa.Super. 2000).
Given the collateral estoppel effect of Brown’s convictions, there can no longer be any
genuine dispute that Brown elevated his personal interests over those of Rite Aid and breached
his fiduciary duties as an offer and director. He was convicted of conspiracy, among other
things, to falsify Rite Aid’s financial statements to qualify himself and other executives to
receive incentive compensation to which they were not entitled and to create back-dated
severance agreements purporting to entitle himself and other executives to additional
compensation to which they were not entitled. He was convicted of deliberately causing false
financial statements for Rite Aid to be filed with the SEC and disseminated to the public. He
was convicted of obstructing Rite Aid, government and grand jury investigations into his and his
co-conspirators’ criminal activities and of suborning a witness to testify falsely to the grand jury.
(Ex. D, Verdict Form, Appendix of Exhibits). These crimes are in violation of Brown’s
fiduciary obligations owed to the company that were inherent in his position as an officer and
director.
Furthermore, the jury made specific findings of fact (Exhibit D, Verdict Form, including
the verdict slip containing specific findings by the jury, Appendix of Exhibits). In its motion,
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Rite Aid quotes certain findings of the jury in support of its claim for breach of fiduciary duty.
These findings establish that Brown breached his fiduciary obligations. Among the findings, the
jury found the following acts were committed in furtherance of the conspiracy of which they
convicted Brown:
39. On or about June 2, 1997, GRASS and
BROWN caused the Company to file its 1997
Proxy Statement with the SEC, which said Report
failed to disclose BROWN’s Amended & Restated
Deferred Compensation Agreement dated October
26, 1996.
44. On or about March 24, 1998, BROWN
instructed a Rite Aid employee to prepare what
purported to be a letter from a member of the
Compensation Committee to GRASS. The letter,
which was back-dated to April 6, 1995, doubled
GRASS’ maximum LTIP I award from 1 million to
2 million shares if the 30 day average price of Rite
Aid stock reached $37.50. At the time the back-
dated letter was generated, the 30 day average
exceeded $33. GRASS and BROWN then caused
the Compensation Committee member’s signature
to be placed on the letter.
88. On or about May 10, 1999 Brown executed a
FY 1999 Proxy Statement Questionnaire in which
he concealed and failed to disclose the enhanced
severance and retirement benefits conferred him by
GRASS’ letter dated May 6, 1998.
117. On or about July 16, 1999, GRASS executed
an Employment Agreement that continued
BERGONZI’s employment with Rite Aid as a
consultant until his retirement on December 31,
2002, at a salary of $525,000 per year and bonuses
totaling $375,000. The Employment Agreement,
which was back-dated to June 15, 1999, enhanced
BERGONZI’s deferred compensation benefits by
paying, upon his retirement, $495,000 a year for
life with a guaranteed minimum 20 years’
payment. The Agreement also Granted
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BERGONZI an unqualified release from liability
for any and all claims stemming from his
employment. In exchange, BERGONZI agreed not
to disclose any “confidential” Rite Aid
information. By separate letter dated July 15,
1999, BROWN clarified BERGONZI was also
eligible to receive long term incentive plan (LTIP)
and stock option awards if such were paid to other
Rite Aid officers.
131. In approximately November of 1999 Brown
instructed his secretary to speak to GRASS’ former
secretary in order to learn how to later the internal
clock on her Rite Aid computer so the file
generation date would match the date on a back-
dated letter.
132. Sometime after GRASS’ resignation on
October 18, 1999, GRASS signed and BROWN
delivered a letter on CEO letterhead dated April 2,
1999, to Eric Sorkin, the Rite Aid officer who had
the lead role in negotiating the BMS and Zeneca
rebate agreements. In addition to stock option
exercise rights, the back-dated letter granted Sorkin
3 years continued salary and bonus upon the
termination of his employment, followed by early
deferred compensation benefits. At the time
Sorkin’s annual salary was $250,000 and his most
recent bonus had been $114,188.
133. On or about Thanksgiving Day, November
25, 1999, Grass signed and Brown delivered a
letter on CEO letterhead dated September 29,
1999, to the residence of another Rite Aid
employee. Although the employee was not an
officer of the Company, the back-dated letter
granted the employee deferred compensation
benefits totaling $525,000 and the right to
accelerate the payment of the benefits in the event
th
he was terminated prior to his 65 birthday.
134. In December of 1999, GRASS signed and
BROWN delivered a letter on CEO letterhead
dated January 8, 1999, to Timothy Noonan. In
addition to stock option exercise rights, the back-
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dated letter granted Noonan continued salary and
his highest annual bonus for 3 years following his
termination or removal from the Presidency of Rite
Aid, followed by deferred compensation benefits
th
for 20 years beyond his 65 birthday. At the time
Noonan was 58 years of age, his annual salary was
$700,000 and his highest bonus had been
$628,600.
Exhibit D, Verdict Form, including the verdict slip containing specific findings by the jury. This
is not an exhaustive list of the specific jury findings either contained in Rite Aid’s Memorandum
in Support of Partial Summary Judgment, or in Verdict Form from Brown’s criminal trial. It
does, however, show specific findings of fact, which Brown is estopped from denying, that are
sufficient to establish Brown’s liability as to Count I of Rite Aid’s complaint (breach of fiduciary
duty).
The jury also found him guilty on Counts 10, 12, 13, 14 and 15 of the Indictment, each
involving the filing of false financial statements to a government agency on behalf of Rite Aid,
including the false financial reports that triggered Brown’s and others’ right to incentive
compensation under the LTIP I. See, Ex. D, Appendix of Exhibits. Brown was found to have
deliberately falsified and submitted false reports to government agencies and to the public. Id.
Rite Aid cites Malone v. Brincat for the proposition that when a director “deliberately
misinform[s] shareholders about the business of the corporation, either directly or by a public
statement, there is a violation of fiduciary duty.” Malone v. Brincat, 722 A.2d 5, 14 (Del. 1998).
As a result of the jury findings, Rite Aid is entitled to summary judgment as to liability on Count
I of their amended complaint, breach of fiduciary duty.
For reasons stated above, in connection with Count I, we believe that Rite Aid is entitled
to summary judgment on Count II, a claim for aiding and abetting breach of fiduciary duty. The
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elements of a cause of action for aiding and abetting a breach of fiduciary duty are: (1) a breach
of fiduciary duty owed to another; (2) knowledge of that breach by the aider and abettor; and (3)
substantial assistance or encouragement by the aider and abettor in effecting that breach. See
Koken v. Steinberg, 825 A.2d 723, 731-32 (Pa. Commw. Ct. 2003) (citing Restatement (Second)
of Torts § 876); Reis v. Barley, Snyder, Senft & Cohen, LLC., 484 F. Supp. 2d 337, 350-52 (E.D.
Pa. 2007) (following the Commonwealth Court’s holding in Koken v. Steinberg and predicting
that “the Supreme Court of Pennsylvania would recognize the tort of aiding and abetting breach
of a fiduciary duty if presented with the issue.”).
Count III is a claim of fraud. To establish common law fraud under Pennsylvania law:
A plaintiff must prove: (1) misrepresentation of a
material fact; (2) scienter; (3) intention by the
declarant to induce action; (4) justifiable reliance
by the party defrauded upon the misrepresentation;
and (5) damage to the party defrauded as a
proximate result.
Colaizzi v. Beck, 2006 Pa.Super. 41, ¶ 9, 895 A.2d 36, 39 (2006). Rite Aid asserts, and is correct
in so asserting, that Brown’s criminal conviction establishes each of the elements of fraud. It
establishes that Brown made material misrepresentations and caused material misrepresentations
to be made concerning Rite Aid’s financial results and the bona fides of the back-dated
severance letters Brown created and had Grass sign after Grass had been discharged by the
company. (See Ex. K, Tr. Of Bergonzi Change of Plea Hrg., pp. 10-15, Appendix of Exhibits;
see also Exhibit D, Verdict Form, including the verdict slip containing specific findings by the
jury). It establishes the scienter requirement, that Brown made such misrepresentations
knowingly and deliberately. The criminal conviction also establishes that such
misrepresentations were made by Brown with the intent to induce Rite aid to rely upon them by
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making payments to him and such other executives under the company’s incentive plans and
under the provisions of the back-dated severance letters. Furthermore, it is clear that Rite Aid
did reasonably rely on such misrepresentations and was damaged as a result (this motion for
summary judgment is only partial in that Rite Aid asserts that it will prove the amount of
damages it suffered as a result of Brown’s fraud at trial, if necessary).
At Brown’s criminal trial, with respect to the claim of fraud, the government presented
testimony of Janene Kope, the secretary who actually typed the letters, that they were dictated by
Brown for Grass’ signature after Grass had been dismissed as Rite Aid’s CEO (Ex. J, Trial Tr.,
pp. 109-37, Appendix of Exhibits). Furthermore, the government offered evidence of Kevinlee
E. Kirsch, a local printer who supplied the stationary on which the back-dated severance letters
were typed that such stationary was not printed until after Grass was dismissed. Id. at 1235-
1251). Furthermore, the jury did find Brown guilty of the back-dating scheme (Ex. D, Verdict
Form, pp. 5-8, Appendix of Exhibits). Lastly, in its ruling in connection with sentencing, the
trial court held that the government met its burden of proof to demonstrate Brown’s
responsibility for the back-dating severance letters. See U.S. v. Brown, No. 1:02-CR-00146-2
(M.D. Pa . Aug. 17, 2004), Memorandum Denying Defendants’ Objections to Pre-Sentence
Investigation Report (Ex. N, Memorandum pp. 10-12, Appendix of Exhibits). As a result of
these findings, Rite Aid is entitled to summary judgment as to liability on the count of fraud.
Count IV of Rite Aid’s amended complaint is a claim of conspiracy. To establish
liability for civil conspiracy in Pennsylvania, a plaintiff must prove: “(1) a combination of two
or more persons acting with a common purpose to do an unlawful act or to do a lawful act by
unlawful means or for an unlawful purpose; (2) an overt act done in pursuance of the common
purpose; and (3) actual legal damage.” McKeeman v. Corestates Bank, N.A., 2000 Pa.Super 117,
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¶ 14, 751 A.2d 655, 660 (2000) (citing McGuire v. Shubert, A.2d 1087, 1092 (Pa.Super. 1998).
Rite Aid cites Watson v. Borough of Darby for the proposition that “[c]ivil conspiracy, like its
criminal counterpart, renders a conspirator liable for the foreseeable acts of co-conspirators
performed to further that conspiracy.” Watson v. Borough of Darby, No. Civ. A. 96-7182, 1997
WL 135701, at *2 (E.D. Pa. Mar. 17, 1997). Furthermore, co-conspirators may even be liable
for tortuous acts committed prior to entering the conspiracy. Daniel Boone Area Sch. Dist. V.
Lehman Bros., Inc., 187 F.Supp. 2d 400, 414 (W.D. Pa. 2002) (applying Pennsylvania law). In
addition to finding Brown guilty of conspiracy, the jury also made specific findings of fact as to
the overt acts that Brown, Grass, Bergonzi and others committed in furtherance of their common
purpose. (See, e.g. Ex. D, Verdict Form, Attachment A, pp. 1-8, Appendix of Exhibits). Rite
Aid addresses Brown’s argument that he should not be liable to Rite Aid for the back-dated
severance letters because he was not aware of all of the wrongful acts committed by his co-
conspirators. Rite Aid responds, persuasively, that as a convicted participant in the conspiracy,
Brown is liable for all of the foreseeable acts committed by his co-conspirators in furtherance of
the conspiracy and the entirety of the resulting damage to Rite Aid. See Sovereign Bank v.
Valentino, 2006 Pa.Super. 338, ¶ 24, 914 A.2d 415, 425 (2006); See also Restatement (Second)
of Torts § 875 (“Each of two or more persons whose tortious conduct is a legal cause of a single
and indivisible harm to the injured party is subject to liability to the injured party for the entire
harm.”).
Count V is a claim for breach of contract (obligations as officer and director). Rite Aid
asserts that in addition to breaching his fiduciary duty to Rite Aid, Brown also breached his
contractual obligations to Rite Aid as Chief Legal Counsel, Vice Chairman and employee. To
establish a claim for breach of contract in Pennsylvania, a plaintiff must prove (1) the existence
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of a contract between the parties; (2) a material breach thereof and; (3) damage to the plaintiff
caused by defendant’s breach. See Omicron Sys., Inc. v. Weiner, 2004 Pa.Super. 389, ¶ 35, 860
A.2d 554, 564 (2004). Rite Aid contends that although Brown did not have a written
employment contract with Rite Aid, as an officer, Chief Legal Counsel and Vice Chairman of the
Board, Brown was a party to a contract implied in fact with Rite Aid under which he was
obligated to zealously protect and act in the best interests of the company. Rite Aid is correct in
establishing an implied in fact contract.
Implied contracts . . . arise under circumstances
which, according to the ordinary course of dealing
and the common understanding of men, show a
mutual intention to contract. A contract implied in
fact ‘is an actual contract, and . . . arises where the
parties agree upon the obligations to be incurred,
but their intention, instead of being expressed in
words, is inferred from their acts in the light of the
surrounding circumstances.
Tyco Electronics Corp. v. Davis, 2006 Pa.Super. 64, ¶ 3, 895 A.2d 638, 640 (2006) (quoting
Cohen v. Marian, 171 Pa.Super. 431, 90 A.2d 373, 376 (1952) (italics original). Rite Aid further
contends that under the inferred terms of the implied in fact contract, it reasonably expected
Brown zealously to protect its interests as its CLO and Vice Chairman, in exchange for the
compensation and benefits Rite Aid paid him. As a result of the facts of Brown’s criminal
conviction, it is clear that he did not act in Rite Aid’s best interests. He acted to advance his
personal financial interests, and he did so by causing Rite Aid to pay substantial sums of money
to him and others to which they were not entitled.
The last count of the complaint is Count VI, a claim of breach of contract (deferred
compensation agreement). Rite Aid seeks to recover payments made to Brown under the
contractual terms of the Deferred Compensation Agreement. Rite Aid asserts that Brown
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forfeited such payments under the terms of the Agreement. The Deferred Compensation
Agreement provided that Rite Aid would have no further obligation to make any payments to
Brown if he were terminated by Rite Aid for good cause or if it were discovered after the
termination of his employment that he committed acts that would have resulted in his
discharging for cause had they been known to the Board during the course of his employment.
(Ex. B, Def. Comp. Agmt., p.8, Appendix of Exhibits). “Good cause” was defined by the
Deferred Compensation Agreement as being “limited to Employee’s conviction of a felony
involving his personal dishonesty materially injurious to the Corporation.” Rite Aid asserts that
the acts for which he was convicted qualify as good cause for the termination of his employment,
and that each of the crimes was a felony involving personal dishonesty and each was materially
injurious to Rite Aid.
As previously stated, Brown was convicted of Count 1 of the indictment, conspiracy to
defraud Rite Aid and its Board of Directors, shareholders, investors and vendors; Count 10,
filing a false SEC Form 10K for Rite Aid’s 1999 fiscal year statement; Count 12, filing a false
1997 Proxy Statement with the SEC; Count 13, filing a false 1998 Proxy Statement with the
SEC; Count 14, filing a false SEC Form 8K on February 9, 1999; Count 15, filing a false 1999
Proxy Statement with the SEC; Count 33, conspiracy to obstruct justice; Count 34, obstruction of
Grand Jury Proceedings; Count 35, obstruction of government agency proceedings; and Count
36, witness tampering. These criminal acts of which Brown was convicted would have given the
Board good cause to discharge Brown. He therefore forfeited any right he might have had to
compensation under his Deferred Compensation Agreement. As such, Rite Aid is entitled to
summary judgment as to liability on Count VI.
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ORDER
th
AND NOW, this 16 day of March, 2010, the motion of Rite Aid for partial summary
judgment on the question of liability with respect to Counts I through VI of its amended
complaint is GRANTED.
BY THE COURT,
_______________________________
Kevin A. Hess, P. J.
William A. Slaughter, Esquire
For the Plaintiff
George Reihner, Esquire
Molly Clark, Esquire
For the Defendant
:rlm
17
RITE AID CORPORATION, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : CIVIL ACTION - LAW
: 02-4922 CIVIL
FRANKLIN BROWN, :
Defendant :
IN RE: MOTION FOR PARTIAL SUMMARY JUDGMENT OF RITE AID CORPORATION
BEFORE HESS, P.J., OLER AND GUIDO, J.J.
ORDER
th
AND NOW, this 16 day of March, 2010, the motion of Rite Aid for partial summary
judgment on the question of liability with respect to Counts I through VI of its amended
complaint is GRANTED.
BY THE COURT,
_______________________________
Kevin A. Hess, P. J.
William A. Slaughter, Esquire
For the Plaintiff
George Reihner, Esquire
Molly Clark, Esquire
For the Defendant
:rlm