Download - BANKING: Borrowers Fight Back With Lender Liability

BANKING: Borrowers Fight Back With Lender LiabilityAuthor(s): DEBRA CASSENS MOSSSource: ABA Journal, Vol. 73, No. 3 (MARCH 1, 1987), pp. 64-68, 70, 72Published by: American Bar AssociationStable URL: http://www.jstor.org/stable/20759189 .

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U



BANKING

BY DEBRA CASSENS MOSS It sounds like an episode from

"Dallas ." A group of hard-nosed bankers embark on a secret plan

to bankrupt two Texas energy compa nies owned by a family of billionaires, in order to gain control of offshore oil drilling.

Wheeling and dealing, the banks leak confidential information to the energy companies' competitors and hold off on restructuring the loans until they can work the best possible terms.

But this isn't a soap opera, and it isn't Bobby and J.R. Ewing. The sons of the late oil billionaire H.L. Hunt, Nelson Bunker, Lamar and William Herbert, have sued 23 banks and lend ing institutions charging that the banks manipulated their loan struc tures in a conspiracy to destroy two Hunt-owned energy companies and create an oligopoly over offshore drill ing.

Though it is not likely to break new ground in legal theory, the drama inherent in this Texas-size ($13.8 bil lion in claimed damages) lawsuit has drawn public attention to an emerging set of legal problems facing the bank ing and lending community. The Hunt brothers' lawsuit embodies virtually every known theory incorporated un der the umbrella of lender liability.

Debra Cossens Moss, a lawyer, is a reporter for the ABA Journal.

Lender liability uses traditional legal theories such as fraud, bad faith, fiduciary responsibility and interfer ence with a business to hold lenders accountable for unfairness in calling a loan or mistakes made in controlling the management decisions of a debtor in trouble.

Plaintiffs' lawyers hail recent lender liability judgments as an im portant curb on the power of credi tors. The other side?banks and fi nancial institutions?foresee huge losses for banks and as a result, more cautious lending policies.

Another question is whether, as critics charge, these suits are filed pri marily as a stalling tactic to give the plaintiffs time to raise funds.

The Hunts' lawsuit was originally filed as two ?separate suits, and then consolidated. The first suit, filed in U.S. District Court in Dallas last June, accuses the banks of trying to destroy the Hunts' Penrod Drilling Company and Placid Oil Company. It seeks $3.6 billion in damages.

The second suit, filed by Penrod Drilling and Placid Oil in July, charges that the same banks engaged in a price-fixing scheme to control off shore oil drilling and seeks $10.2 bil lion.

THE THEORIES The lawsuits proceed on a litany

of lender liability theories: wrongful control, domination, economic coer

cion, bad faith, breach of fiduciary duty, breach of contract, fraudulent misrepresentation, and violation of the Sherman Antitrust Act, the Bank Holding Company Act, and RICO.

The lawsuits include allegations that:

The banks controlled Penrod and Placid's affairs to their own ad vantage, and delayed loan restructur ing to force the companies to agree to unreasonable terms, such as a pay ment schedule that could not be met and a pledge of additional assets as collateral.

Many of the banks granted concessions and gave better credit terms to other customers, some of them Penrod and Placid competitors.

Several banks promised to re structure Penrod's loan before Febru ary 1986, but intended to break that promise.

Some Placid creditors dis closed confidential information to po tential bidders for property that Placid was attempting to sell to pay off its debts, and "sabotaged" efforts by Placid to refinance its debt with an other bank.

The banks drafted a secret plan in March 1986 to create and con trol an offshore oil drilling oligopoly. By exercising certain creditors' rights, the banks would determine which borrowers would survive, and obtain ownership interests in those compa nies.

?4 William Herbert Hunt, Left, and Nelson Bunker Hunt charge that banks have con

spired to destroy their energy companies.

ABA JOURNAL / MARCH 1, 1987 ?5



BANKING

Penrod was invited to partici pate in the secret plan, but refused, prompting the banks to retaliate by attempting to destroy Penrod.

Far from conceding any points, the banks denied the charges, and filed counterclaims seeking payment of about $1.5 billion borrowed by the Hunt companies, and moved for sum

mary judgment on the claims. The lender liability theory of the

Hunts' lawsuits is a recent phenome non. Lender liability first attracted widespread attention in 1984, when the Texas Court of Appeals affirmed the result (although it reduced the $18.9 million award to $18.6 million) in State National Bank of El Paso v.

Farah Manufacturing Co., 678 S.W.2d 661.

"At that time, when Farah was

decided, we really thought it was a

fairly isolated event," said Maury Poscover of Donohue, Cornfeld & Jen kins in St. Louis. "Now there are liter ally stacks of lender liability cases

coming in. And it isn't just going one way?a few of them are good case law for the lenders, limiting the scope of their liability."

A. Barry Cappello, a Santa Barbara, Calif., attorney who won a

multimillion dollar judgment against Bank of America in a lender liability suit, said he receives about 10 phone calls a week from borrowers who would like him to represent them.

Cappello says the big increase in these lawsuits may be caused by sev eral factors, including a poor econ

omy, and publicity about large judg ments.

Many lawsuits are brought by farmers who fell victim to the farm crisis, he said. Farmers who borrowed

heavily when the value of their land was high are now suing their banks when the banks call the loans or insist on changes in the farmers' manage ment. The weak economy also affects the banks, spurring them to call loans they would continue to hold in more prosperous times.

"When there's good times, the banks work with their borrowers, roll over the loans, work it out, find an other lender for them," Cappello said. "But when times are tough you've got some banks in the country that are in financial trouble, and they move pre cipitously against the borrower."

Farah and the cases that fol lowed established three primary areas

66 ABA JOURNAL / MARCH 1, 1987

iB^^Hl^ ^^^^^^^^ A. Barry Cappello, the Santa

Barbara, Calif., attorney who won a multimillion dollar judgment against Bank of America.

of lender liability: controlling and in terfering in a borrower's affairs; not dealing with a borrower in good faith; and misrepresentation and fraud.

MANAGEMENT CHANGE CLAUSES The Farah case dealt with bank

interference, duress and fraud.

The dispute centered on William Farah's bid to become CEO of Farah Manufacturing, a clothing manufac

turer. A management change clause in the loan agreement gave any two banks veto power over any change in the executive management of Farah, if they considered the change, "for any reason whatsoever, to be adverse to

the interests of the banks." Any change that occurred despite the banks' objections could be treated as a default.

The lenders, basing their author ity on that clause, told company direc tors that Farah was unacceptable, and if he were elected CEO, the banks

would bankrupt Farah Manufacturing, and padlock it the next day.

Under the management of two lender-backed CEO's, the company's position in the market deteriorated, and Farah assets were sold to pay interest and reduce the outstanding liability on the loans. Some equipment

was sold to Farah competitors, with one of the Farah lenders financing the

competitor's purchase before Farah regained control as CEO.

The Texas Court of Appeals said that Farah lenders went too far in con trolling Farah management. "Al

though the lenders may have been acting to exercise legitimate legal rights or to protect justifiable business interests," the court said, "their con

duct failed to comport with the stan dards of fair play.. . . [Farah] was enti

tled to have its affairs managed by competent directors and officers.

The court also upheld a fraud claim based on a bank's warnings that it would declare the loan in default

when in fact the bank either had made no decision on the matter, or did not plan to call the loan.

The court also upheld a duress claim based on the warnings that Farah would be bankrupt and pad locked the next day if Farah were in stalled as CEO.

DUTY OF GOOD FAITH Although no separate claim was

made for breach of good faith, the court discussed good faith in its opin ion, saying a threat made in bad faith can be considered duress and that the lenders should have acted in good faith rather than making the false and

misleading warnings. The good faith theory got a big

boost in a 1985 decision, KMC. Co. Inc. v. Irving Trust Co., 757 F.2d 752 (6th Cir.), upholding a $7.5 million jury award that included punitive damages.

K.M.C., a food broker in Knox

ville, Tenn., alleged its bank failed to advance funds under a loan agree ment. The Sixth Circuit said the obli gation of good faith implied in every contract covered by the U.C.C. im

posed a duty on the bank to give no tice before discontinuing financing, even though the bank had a discre tionary right to make advances.

Since KMC, the good faith the ory has been the basis of many lender liability lawsuits, focusing primarily on the establishment of a course of dealing between the bank and the borrower that the borrower expects to continue despite strict enforcement provisions in the loan agreement.

"The hottest new area of lender liability is a widening of the breach of the duty of good faith and fair deal ing," said Cappello, a partner in the

4



law firm of Cappello & Foley. "There have been a rash of law

suits that have held that under the U.C.C. there's a good faith duty to ne gotiate and to give the other party time to find a new source of finance in the situation in which a bank may be pulling its line of credit from the bor rower," said Phoenix, Ariz., attorney Robert E. L. Walker, who chairs the ABA Banking Law Committee.

Some borrowers are going be yond allegations of breach of good faith, and claiming the lender

breached a fiduciary relationship.

LENDERS AS FIDUCIARIES In an Ohio case, Dennis v.

BancOhio National Bank, No. 18738 (Perry County), Columbus attorney J. Stephen Teetor claimed the financial problems of his farmer clients were caused when the bank breached a fi duciary relationship. A jury found for Teetor's clients, Keith and Nancy Dennis of Rushville, Ohio.

The jury awarded the Dennises $1.04 million, but the amount was to

be offset by the amount of the loan? about $700,000. The case was later settled under undisclosed terms to avoid appeal.

Teetor, of Isaac, Brant, Ledman & Becker, argued that the bank assumed a fiduciary relationship when it began to advise the Dennis family on how to run their farm?advice that resulted in financial losses.

"Bank personnel began advising Dennis as to when and how to market products, how to run and manage the farming operation, and assisted plain

ABA JOURNAL / MARCH 1, 1987 67



BANKING

tiffs to prepare and analyze their fi nancial matters," Teetor said in his trial brief. "In fact, the bank even went so far as to order that plaintiffs fire their independent marketing consul tant."

The trial judge sent the issue of breach of fiduciary relationship to the jury, along with issues of whether the bank exerted economic duress to get the Dennises to follow its advice, and whether the bank was negligent in structuring loans.

In what may be the largest lender liability verdict to date, the Jewell family, which owns an apple orchard in California, won $46.6 million in a lender liability suit against Bank of

America in 1985. The trial judge re duced the amount awarded to $22 million, and an appeal is pending. Kruse v. Jewell v. Bank of America, No. 112439 (Sonoma County).

In the Jewell case, the apple growers argued at trial that the bank agreed to provide long-term financing, prompting the Jewells to turn over more collateral to the bank. Then, after security was given, the bank re fused further financing, which the Jewells said destroyed their business.

THE POLICY ISSUE Some lawyers are questioning

the policy behind the decisions. Is it right to hold bankers liable for lack of good faith? What do the new decisions mean for bank lending policies?

"I think the banking industry, like everybody else that deals in the business world, ought to be held to standards of reasonableness," says Teetor. "When a bank comes in and tells you how to run your business, and you lose money, the bank ought to be responsible for the loss."

Lenders do not assume a fiduci ary relationship in every transaction, Teetor says, but in some cases they do. "If the relationship evolves into one of special confidence and trust, the bank owes special duties.

"It doesn't mean the bank is going to be responsible for everything that goes wrong," he says. "It means

they're going to have to exercise their judgment in the best interest of the customer."

W. Ted Minick, attorney for one of the Hunt defendants, the First Na tional Bank of Chicago, criticizes ap plication of the fiduciary duty theory to the creditor-debtor area. Many bor


A J. Stephen Teetor: If a lender bank tells farmers how to farm, it is as

suming a fiduciary relationship.

rowers, he says, are "big boys" who

don't look to the lender for advice. Critics charge that lender liability

will create unforeseen bank losses should the new lender liability prevail.

"The thing I find disturbing is the allowance of punitive damages against the bank," said Helen Davis Chaitman, chairperson of the ABA's Creditor Lia bility subcommittee. "We're getting huge punitive damage verdicts. This is a problem for the industry, because there's no way a bank can figure into its pricing structure the cost to the in stitution of a punitive damage award."

Large punitive damage awards can be "devastating" for a small bank, said Chaitman, of Wilentz, Goldman & Spitzer in Woodbridge, N.J.

ABA Banking Law Committee chairman Walker charges that fear of lender liability losses will force banks to give fewer loans to those with mar ginal credit ratings, such as entrepre neurs, small businesses, and major

corporations with temporary financial problems.

"You have to be much more care

ful with documentation," agreed one of the banks' attorneys. "Credit is sim

ply not going to be available in some areas."

Edwin A. McCabe, who filed the Hunt lawsuits but was replaced in De

cember, hopes courts that follow the lender liability trend will go even fur ther and rule that banks should not be allowed to favor one borrower over an

other.

Traditionally, banks dealt with each borrower on its own merits. McCabe says that's wrong?banks should "not have the total flexibility to decide, as they do today, who lives and who dies."

That "absolutely ignores reality," says Minick, of Winstead, McGuire, Sechrest & Minick in Houston, Tex. Credit decisions must be made with out regard to loan agreements with other borrowers, he says. Banks must look at "a whole bevy of factors" about the individual borrower, such as as sets and cash flow.

A STALLING TACTIC? Critics also charge that many

lender liability suits are filed to delay bank foreclosures, and to give the bor rower time to work out an agreement with his lender.

"Some of the litigation is clearly intended as a vehicle for delaying lender action," says Poscover, chair

man of the ABA's Commercial Finan cial Services committee. "But before banks initiate deficiency actions, they need to measure their liability. In fact, in several cases where liability was found, the deficiency suits were the source of the counterclaim for lender liability."

Those states where borrowers have been most successful in receiv ing large judgments are California, Texas and Florida. Bad faith claims play well to California courts, but, de spite the dicta in the Farah decision, plaintiffs should proceed on another theory in Texas, Poscover said.

Despite the large verdicts, a lender liability lawsuit can be risky, and an attorney must carefully screen the case before taking it, said Cappello.

"In personal injury litigation you have a scarred or burned or terribly injured plaintiff, and the issue is usu ally damages," Cappello said. "Here the issue is liability. You have someone who physically is fine, but his economic life has been de stroyed.

"The banks have the finest blue chip law firms in the nation; they put teams and teams of lawyers against you," he continued. "It requires a tre



BANKING

Hunt Lawyer Gets Record Fee

The Hunts are paying top-dollar legal fees of $600 an hour to the man

aging partner of their newly hired Houston law firm, Susman, Godfrey & McGowan. The fee is more than three times the hourly rate charged by most Texas lawyers.

"Frankly, I think I am three times better than some of the people who bill the lower hourly rates," said attor ney Stephen Susman.

He confirmed that all attorneys in his firm will be billing a 50 percent premium in the Hunt case. Susman's base rate is $400 an hour, partners bill an average rate of $203 an hour, and associates bill an average $96 an hour.

"Our average partner hourly rate and our average associate hourly rate are lower than other firms," Susman said. "I could lower my rate to $200 an hour, and raise everyone else's rate, and it would not attract any attention."

Susman says he charges more than other members of his firm to en courage clients to use younger lawyers on matters "that don't require my expe rience and abilities."

He is charging a 50 percent pre mium because the 22-lawyer firm will have to devote a large part of its re sources and manpower to the case.

Susman, Godfrey & McGowan is trans ferring other cases to outside attorneys at additional expense, and limiting the number of new matters it takes on, he said.

Lawyers for banks involved in the Placid Oil Chapter 11 action objected to the rates. But the bankruptcy court approved the fees, as long as no more than $250 an hour is billed to the Hunt trust and companies seeking bankruptcy protection. The rest will be paid by other Hunt entities.

Susman admits to initial hesita tion regarding the Hunt case. "My per ception of the case fostered by the media, was, 'here's some rich guys from

Dallas who are trying to avoid paying banks some money that they owe,'" he said.

Now that Susman has reviewed the case, he thinks it's clear that the banks "did things here that went be yond the bounds of propriety."


"The banks had a secret agenda to wait until these loans were in trouble, and then to come in and ask the Hunts individually or related Hunt entities to put up collateral," he said. "We think the banks set out systemati cally to get their hands on the Hunt trust assets even though they knew they didn't have any right to."

Susman says the Hunt brothers have not told him the reason for dis missing McCabe/Gordon of Boston. However, that firm's early losses and geographic distance from the trial may have entered into the decision.

"If the trial lawyer is not winning, the fact that he's working his rear off and doing a good job doesn't give him any brownie points," Susman said.

Also, many banks objected to the huge travel expenses being incurred by McCabe/Gordon. "Quite frankly, I think it's a very difficult job to handle a case so far from home," he said.

Susman is well aware that the case will generate lots of publicity.

"Every time you take on a case that's high visibility, if you lose it, it's a

big loss. If you win it, it's a big win. That's why it's a professional gamble."

Susman has received publicity on some other high profile cases, includ ing the In re Corrugated Container price fixing suit against 37 corrugated container manufacturers that was set tled in 1982 for $550 million.

Susman, Godfrey also won $9 mil lion in an antitrust suit against Hous ton and several cable TV companies for a cable TV company that was denied the right to a franchise; reached a $50 million settlement for Northrop Corp. in a contract and antitrust dispute con

cerning the F-18 jet fighter against McDonnell Douglas Corp.; and reached a $45 million settlement in a securities fraud class action filed by Houston Oil Trust shareholders.

Susman graduated magna cum laude from Yale University in 1962, and

with highest honors from the Univer sity of Texas law school in 1965, where he edited the Texas Law Review.

He clerked for both the U.S. Court of Appeals for the Fifth Circuit and the U.S. Supreme Court. He for merly worked at Fulbright & Jaworski, where he became a partner in 1973. Susman, Godfrey & McGowan was first established in 1980.

?Debra Cossens Moss

mendous amount of capital on behalf of the plaintiff's attorney, it requires thousands and thousands of docu

ments, and complex business transac

tions that have to be explained on a

simple basis to the jury." Cappello, who works on a contin

gent fee basis, says he will only accept cases from "credible" plaintiffs who have suffered or will suffer significant damages, because a lender has "over

reached in the transaction, been un

reasonable, arrogant, and has treated

the lender-borrower relationship with disdain."

Not all lender liability cases are won on appeal, either. A $4.5 million trial court award for a borrower was

overturned in Centerre Bank of Kan sas City v. Distributors, Inc., 705 S.W.2d 42 (1985).

In that case, the Missouri Court of Appeals refused to impose the obli gation of good faith on a bank contract which gave the lender the right to call in a loan on demand.

"The imposition of a good faith defense to the call for payment of a demand note transcends the perform ance or enforcement of a contract and

in fact adds a term to the agreement which the parties had not included," the court said.

However, the court also noted that the bank had given the borrower several months' notice of its intent to call the loan, and tried to help the bor rower obtain other financing.

Some courts have refused to allow punitive damages in suits based on the good faith obligation. For ex

ample, Rigby Corp. v. Boatmen's

Bank and Trust, 713 S.W. 2d 517 (1986), held that the U.C.C. did not in tend an independent cause of action in tort for a breach of good faith, and therefore barred punitive damages on that theory. Plaintiffs may be able to get these damages on other theories, however, such as fraud.

Now that lender liability has gained a toehold, it may become eas ier to win lender liability suits.

Poscover says borrowers who win

suits today usually allege a series of egregious acts committed by the lender. As the new theory gains ac ceptance, borrowers may win even

when there is only a single egregious wrong by the lender.

But lender liability theories have not helped the Hunt brothers yet. Placid Oil filed for bankruptcy protec



BANKING

tion under Chapter 11, despite the fil ing of the suit.

In December, the Hunts replaced the Boston firm representing them,

McCabe/Gordon P.C., with the Hous ton firm of Susman, Godfrey &

McGowan.

The Hunts lost one early legal skirmish in August, when U.S. District Court Judge Barefoot Sanders refused to issue a temporary restraining order to prohibit bank foreclosures on Hunt collateral.

"Taken to its logical conclusion," Sanders said, "the principle that movants propose would forestall all foreclosures at precisely the times when the remedy of foreclosure is usually most needed by lenders, i.e., when the market is depressed. Such a result is untenable."

Sanders also said that at this early stage, he did not see a likelihood of success on the merits sufficient to restrain foreclosure. The Hunts would

Defensive Lending Bankers are learning how to avoid

lender liability lawsuits with a new vid eotape called "Sue the Lender." It's produced by BancVideo with the assist ance of the ABA's Commercial Finan cial Services subcommittee.

Here's some advice for lenders contained in the videotape and pro gram materials.

Some restrictive covenants in the loan agreement, such as the right to veto a borrower's large financial trans actions, are usually safe. But stay away from clauses that allow the lender to make management decisions or to con

trol normal day-to-day activities.

Avoid loan agreements that give the lender the right to fill specific board seats, and don't use board con

trol clauses to get people elected to the board who will serve the lender's interests rather than the shareholders'.

Even though the agreement may give the lender the right to call the loan, do not threaten to collect in order to force management changes or to compel the debtor to act for the lender's benefit.

If a loan begins to deteriorate, you may be able to give the borrower advice if he asks for it. But don't threaten default to get the borrower to


"face difficult hurdles" such as the ap plication of the parol evidence rule to breach of contract claims, he said.

The court also anticipated prob lems on the fraud and bad faith claims, citing cases holding that "trickery, ar tifice or device" must be shown to es tablish fraud, and that Texas has no requirement of good faith and fair dealing in a mortgage contract be tween two parties who were attor

neys.

"Further, for the court to find a substantial likelihood of success on the merits with respect to Movants' claim for wrongful domination and control and economic duress would require the Court to determine Movants acted with a degree of na ivete which is belied by their own affi davits," Sanders said.

When the banks proceeded to foreclose, Placid Oil filed a petition for Chapter 11 protection in New Or leans.

follow your advice. You may be able to suggest possi

ble candidates for a consulting position when a loan begins to falter, but don't choose the consultant.

Avoid personality conflicts with the debtor. Act professionally at all times.

Maintain proper credit files, re

membering that they could be used as evidence in court. The file should sup port your actions, contain only the facts and not subjective comments about the borrower, and contain good notes of your conversations with the borrower.

Many loan agreements give the lender the right to stop advancing funds or to change the amounts ad vanced. But a course of dealing may change these rights. Give reasonable notice before changing the way a dis cretionary advance clause is adminis tered.

Many loan agreements give the lender the right to demand full pay

ment at any time. But these clauses must be applied reasonably and when appropriate. Give reasonable notice be fore accelerating a loan.

If you have neglected events of default in the past, give reasonable written warning before enforcing them in the future.

Seek legal counsel before taking

Sanders, having ordered all re lated Hunt legal matters to remain in his jurisdiction, ruled that the bank ruptcy proceeding must be moved back to Dallas, and the U.S. Court of Appeals for the Fifth Circuit agreed. McCabe/Gordon agreed to discon tinue its role in the bankruptcy case in October.

The politically conservative Hunts have tried to remove Sanders from the case, citing philosophical dif ferences and Sanders' ownership of stock in a bank holding company not involved in the case. The Fifth Circuit ruled against the Hunts, and their at torneys are unsure if they will ap peal.

Whether the Hunt brothers or their creditors prevail, though, Poscover contends that the world of banking should be neither shaken nor smug. "If banks are sensitive to the is sues and careful," he said, "they can avoid all these problems."

any enforcement action against a debtor.

Don't make oral promises. When you receive a credit in

quiry, check the facts first, then re spond honestly and tell the complete truth. Your response should stick to facts such as account and loan bal ances, collateral and payment history, and should not address things like the debtor's character.

Threatening to call a loan when such a decision has not been made could be construed as fraud, even if the loan agreement gives you the right to call a loan at anytime. Don't threaten to call a loan if you don't in tend to call it.

Don't misrepresent your loan pol icy to the debtor, and don't use it to get the debtor to follow your wishes.

For more information on "Sue the Lender," call BancVideo at (314) 968-0220.

Lawyers, as well as lenders, are educating themselves on the latest trends in lender liability law. The ABA's Section of Litigation and Section of Corporation, Banking and Business Law sponsored three national institutes on lender liability in 1985, and offered a three-volume set of course materials.

The next program on the subject will be held in April in San Diego.

?Debra Cossens Moss



Download - BANKING: Borrowers Fight Back With Lender Liability

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