MOTIONS OF GERALD K. SMITH TO AMEND THE TEXT AND

COMMENTARY OF § 5.04 OF TENTATIVE DRAFT NO. 6

OF THE RESTATEMENT OF THE LAW OF AGENCY

 

MOTION 1.

I move that the text of § 5.04 be amended by substituting for “intending to act solely” for his own or another’s purpose the language of Tentative Draft No. 4 (March 17, 2003), which more broadly provided that the adverse interest exception applies “if the agent acts adversely to the principal in a transaction or matter for the agent’s own purposes or those of another person.”

For purposes of determining a principal’s legal relations with a third party, notice of a fact that an agent knows or has reason to know is not imputed to the principal if the agent acts adversely to the principal in a transaction or matter, intending to act solely for the agent’s own purposes or those of another person.

MOTION 2.

I move that the second sentence of Comment c of § 5.04 be deleted:

When an agent acts adversely to a principal.  The term “adversely” is not free of ambiguity.  However, for purposes of common-law agency, the fact that an action taken by an agent has unfavorable results for the principal is not relevant.

MOTION 3.

I move that Comment d be amended by adding after the second sentence “Thus, if a principal sues to enforce an agreement obtained by an agent through fraud on a third party and the principal knows of the fraud, notice is imputed to the principal of facts that the agent knows or has reason to know and adding after the third sentence of Illustration 8 the following: “P Corporation’s sales managers investigate, discover the facts of A’s conduct, and refuse to return T’s payment.”

d. Benefit of agent’s action knowingly retained by principal. The adverse-interest exception serves to shield a principal against imputation of notice of facts known to an agent who acts adversely to the principal. The exception should not serve as a sword that enables a principal knowingly to retain the benefits of its agent’s wrongdoing. Thus, if a principal sues to enforce an agreement obtained by an agent through fraud on a third party and the principal knows of the fraud, notice is imputed to the principal of facts that the agent knows or has reason to know. Closely related principles determine whether a principal has ratified an agent’s conduct. See §§ 4.01 (Tentative Draft No. 2, 2001) and 4.07 (id.). Whether a principal has retained a benefit is at least in part a question of fact.

Illustration 8 would read as follows:

8. Same facts as Illustration 7, except that T pays P Corporation for the furnace, paying 50 percent more than the list price, as demanded by A.  After the furnace is delivered to T, T discovers that its condition is as stated on the price list. T demands that P Corporation return the payment made by T in exchange for the furnace. P Corporation’s sales managers investigate, discover the facts of A’s conduct, and refuse to return T’s payment. P Corporation is charged with notice of the fact known to A that the condition of the furnace was as stated on the price list.

MOTION 4.

I move that the Comment to § 5.04 include a discussion of the adverse domination doctrine by the addition of Comment e of § 5.04 of Tentative Draft No. 4.

discussion of proposed amendments

A.   The Adverse Interest Exception Should Not Be Limited To Cases Where The Agent “Intends To Act Solely” For Himself Or Another.

Section 5.04 (“An agent who acts adversely to a principal”) creates an exception to the general rule regarding imputation of an agent’s knowledge to the principal. Tentative Draft No. 6 would limit the exception to situations in which the agent is determined to have “intended to act solely” for his own or another’s purpose. 

Application of this narrowly defined “subjective intent” test, which applies only when the intent is to act “solely” for the agent’s own purposes would make it far too easy for third parties, such as auditors, to escape liability to the corporation. Under the current draft, when any subjective intent to benefit the principal is found, the case is closed. This rule could have devastating effects in the typical corporate fraud case in which corrupt corporate insiders falsely overstate the corporation’s financial condition. The corporation appears to be growing and profitable, when it is in fact insolvent and sinking ever deeper into debt. Case law throughout the country has recognized that artificially prolonging a corporation’s life is a detriment, not a benefit, to the corporation.

Under the narrow and rigid language of the present draft, imputation would be the order of the day, even if the primary purpose of the insider in question was to loot, steal, and dissipate the corporation’s assets or conceal previous wrongdoing.

Moreover, the law of imputation which has developed has not focused on an analysis of the corrupt corporate insider’s motivations in order to determine his or her “subjective intent”; rather, as set forth in the seminal cases of Schacht and Cenco, the analysis of whether imputation is proper is quite different. Instead of focusing on the intent of the corporate insiders, Schacht employs the following analysis, and addresses the following considerations:

·                    As a threshold matter, have the managers of the corporation turned the company “into an engine of theft against outsiders?” 711 F.2d at 1347.

·                    Has the corporate insiders’ misconduct “clearly benefited the corporation,” thereby making the case “ripe for an analysis of whether the directors’ knowledge of the fraud should be imputed to the benefited corporation”? 711 F.2d at 1347. (In the absence of such a benefit to the corporation, Schacht held that the “Cenco analysis, which seeks to determine the propriety of imputing to the corporation the directors’ knowledge of fraud,” was not “even trigger[ed].” Id. at 1348.)

·                    Assuming that the “engine of theft” and “benefit to the corporation” thresholds have been met, will “a judgment in favor of the plaintiff corporation … properly compensate the victims of the wrongdoing, and … deter future wrongdoing”? 711 F.2d at 1348.

Thus, in neither of what are generally considered to be the two leading cases on imputation — Schacht and Cenco — does the court follow the “agent’s subjective intent” approach, as set forth in the Draft, which focuses entirely on whether the trier of fact can be persuaded that the corporate insider had the requisite “one percent of subjective motivation” to benefit the corporation. Rather, the analysis in these cases, and in the majority of cases which followed them, runs along well-considered lines of public policy and equity. In other words, given the totality of the circumstances, would the public, including the innocent shareholders and creditors of the corporation, be better served by allowing the corporation to bring suit against these third parties, or was the corporation nothing but an “engine of theft” or a “Ponzi scheme,” or so thoroughly dominated by corrupt directors and officers, that it would indeed be inequitable and poor public policy to allow such an entity to bring claims against its proverbial partners in crime? 

B. The Statement That Adverse Consequences Are Irrelevant To Imputation Should Be Deleted.

Comment c states that “the fact that an action taken by an agent has unfavorable results for the principal is not relevant.” This sentence should be deleted from the Comment. The results of the agent’s acts and the harm to the principal are relevant to establish that the agent’s acts were adverse and that the agent acted for his own or another’s purpose.

C.  The Comments Should Unambiguously State That A Principal Can Only Ratify An Agent’s Adverse Conduct When He Has Actual Knowledge Of The Wrongdoing.

Prior drafts of § 5.04 (including Draft No. 4) included Comments and Illustrations which clearly stated that ratification of an agent’s adverse acts applied when the principal had actual knowledge of the misconduct. These Comments and Illustrations have been removed from Draft No. 6, suggesting that a principal may ratify conduct adverse to it even it if is unaware of the agent’s adverse activities. 

This is a significant departure from the current state of the law. Restatement Second of Agency § 282 requires that the principal “knowingly” retain a benefit of an agent’s adverse act.

D.  Section 5.04 Should Include A Comment On The Adverse Domination Doctrine.

The Proposed Amendment includes a Comment on the adverse domination doctrine that was included in Tentative Draft No. 4. The adverse domination doctrine holds that the statute of limitations does not begin to run until a corporation has a majority of its directors who are not culpable. This Comment should be included because it is helpful in understanding the adverse interest exception and its relationship to the adverse domination doctrine.