QUESTIONS PRESENTED FOR REVIEW

 

 

1.      Whether the defendant _____ had authority, actual or apparent, to bind

__________to the mortgage given to plaintiff _________?

            2.  Whether plaintiff had established any basis on which the court may find equitable estoppel?

            3.  Whether the answer filed by ____ and full and complete discovery provided plaintiff with sufficient information concerning defendant’s allegations as to ___ having exceeded his corporate authority?

 

 

 


 

COUNTERSTATEMENT OF FACTS

 

                The record shows that the transaction that is the subject of this action was a personal one between plaintiff and _____ (R-649) (644) (293-294).  Defendant negotiated the terms on his own; he signed the contract in his own name (R-106-107); he applied to ____ on his own for a mortgage loan (R-633); took occupancy prior to closing on his own behalf (R-114-115); he negotiated the second mortgage loan with plaintiff on his own and he never disclosed it to his brother or his father, the other shareholders of the corporation; defendant took title in his own name (R-644); and he alone dealt with plaintiff when payments were missed.  Plaintiff testified he considered the transaction a personal one and that he considered the debt to be defendant’s personal debt.  Plaintiff admitted he knew ____ and ____ were equal owners of ___ along with defendant and that he knew them personally (R-136-141).  Notwithstanding that knowledge he also admitted that he never contacted either co-owner prior to the execution of the Note and Mortgage and further, that he never contacted them regarding the defaults in payments until formal demands were made by his lawyers in 1995 (R-136-141) (151-152) (147) (161).

            The Note and Mortgage to plaintiff was solely for the purpose of completing defendant’s personal transaction.  No benefit was conferred by this transaction upon ___.  It received nothing in exchange for its purported mortgage obligation.  Plaintiff has argued that ____ benefited because he got to use the sheet metal equipment housed in the building.  This is an unrealistic theory since the ___ claimed they still owned the equipment and more importantly, he paid defendant rent (R-524-528).  As to ___, no illustration was offered by plaintiff as to how he was benefited by the transaction between defendant and plaintiff.  It cannot be said that the instrument signed on behalf of ___ was supported by any consideration to the maker thereof.

            Plaintiff argues that defendant had both actual and apparent authority to execute the Note and Mortgage on behalf of ___.  He claims that __ had authority to execute agreements in the ordinary course of ___ business and that the mortgage to plaintiff falls into that category.  While executing a note and mortgage was a permitted or authorized act for the corporation, it is not the same as its “ordinary course of business.” 

            The ordinary course of business of ___ was not borrowing money and executing mortgages.  ___ ordinary course of business was owning and operating the property it owned in ___.  Mortgaging that property for defendant’s personal benefit was not part of running that business.

            The other actions by the shareholders referred to by plaintiff do show certain transactions were made which benefited the individual owners, and sometimes corporate formalities were overlooked, but all of those transactions were undertaken with the knowledge and consent of all the shareholders (R-538-553).  All the actions cited by plaintiff were mutually consented to – the subject’s mortgage to plaintiff was not.

            Prior to the transaction in question, plaintiff had no dealings with ___ whatsoever.  He had no conversations of any business substance with any shareholder of ___ until he began negotiating with defendant for the sale of his property.  Plaintiff never communicated with anyone who had an interest in ___ other than defendant (R-136-141).  Except for defendant’s self-serving statement, plaintiff had no indication of defendant’s authority to perform any acts for the corporation (R-140), and particularly an act, which benefited only ___ personally.  Plaintiff seeks to rely upon the awareness that his former attorney, ___, claims to have had as to defendant’s authority (R 135-141).

            As of _____, 200_, ___ was aware of three prior loan transactions involving the family.  The loan document for the first was signed by ___ and ___; the second was signed by defendant; and the third was signed by all three family members.  Each transaction was for institutional financing of corporately owned property (R-208-209) (213-217) (239-241).

            ___ testified that he didn’t know who the shareholders of ___ were as of July 19, 1990.  He assumed defendant was authorized, essentially because defendant said he was (R-291-300) and because he said transactions involving ___ were handled by defendant prior (R-292).  The evidence shows, however, that there was only one loan transaction involving ___ and ___ where only defendant acted for ___.  Further, and most importantly, the subject transaction did not benefit or involve ___ (the corporation) – it only involved defendant.

            Plaintiff failed to inquire beyond defendant’s self-serving representation, and he failed to request the consents of the other two shareholders.

Plaintiff asserted in its Brief (PA Brief page 6) that ___ “appeared to include” the mortgage liability in its tax return.  This is reasserted at PA Brief, pages 28 and 45.  This representation distorts the actual matter as it was presented to the Court.  ___ indicated he did not know what the entry reflected (R-605-606) and a review of the return (R-812 et seq) does not specify or identify the item.

 

 

 

 

Point I

THE DEFENDANT ________ HAD NO AUTHORITY, ACTUAL OR APPARENT, TO BIND ___ PROPERTIES, LTD. TO THE MORTGAGE GIVEN TO PLAINTIFF BRUCE J. LINDENBAUM.

 

As a general rule, in order that a corporation may be bound by the acts of one as its officer or agent in executing a note and mortgage upon the ground of apparent authority or estoppel, it must appear that the corporation is chargeable with notice or knowledge of the acts relied upon to establish such apparent authority or estoppel.  18B Am. Jur. 2d, Corporations sec. 1528.

Generally, persons dealing with the officers and agents of a corporation are required to take notice that the latter’s powers are derived from statutes, bylaws or usages which define the extent of their authority, and in doubtful cases, one must acquaint himself with the exact extent of that authority.  Traitel Marble Co. v. Brown Bros., Inc. 159 A.D. 485, 144 N.Y.S. 562 (1913).  Plaintiff was aware that the Note and Mortgage was to secure a purchase of property personal to defendant.

In the determination of authority conferred upon officers by boards of directors, the minutes of the meeting of the directors and formal resolution of the board are the best evidence.  18B Am. Jur. 2d, Corporations sec. 1632.  However, a formal resolution is not the only evidence of corporate action; everything that is said and done and the entire setting of the occasion may help in determining the authorization intended to be conferred on a corporate agent and the purpose to be carried out and effected.  Geotel, Inc. v. Wallace 162 A.D. 2d 166, 556 N.Y.S. 2d 577, app dismd, app den 76 N.Y. 2d 917, 563 N.Y.S. 2d 55, 564 N.E. 2d 665 (1990, 1st Dept).  The extent of a corporate agent’s authority is not to be established by his own representations.  Wolper v. New York Water Service Corp. 276 A.D. 1106, 96 N.Y.S. 2d 647 (1950); Loeb v. Star & Herald Co. 187 A.D. 175, 175 N.Y.S. 412 (1919); Witt v. Carlton Dress Goods Co. 156 N.Y.S. 693 (1915, Sup App T).

In an action against a corporation under a contract made with an officer or agent, direct authority must be shown in the officer or agent to make such a contract on behalf of the corporation, or facts must be shown from which such authority would be presumed.  N.A. Berwin & Co. v. Hewitt Realty Co. 199 A.D. 453, 191 N.Y.S. 817, affd 235 N.Y. 608, 139 N.E. 754 (1922); Coney Island Automobile Race Co. v. Boyton 87 A.D. 251, 84 N.Y.S. 347 (1903).

The making of a contract by officers of a corporation will not in the first instance be presumed to be within their authority unless the contract is one within the power of the corporation itself to make, and one in the general course of its business.  N.A. Berwin & Co. v. Hewitt Reality Co. 199 A.D. 453, 191 N.Y.S. 817, affd 235 N.Y. 608, 139 N.E. 754 (1922).  The mere fact that a corporation has the power to make a certain type of contract does not, of itself, clothe even the highest officer of a corporation with apparent authority to bind the corporation to such a contract.  18B Am. Jur. 2d, Corporations sec. 1542.  Moreover, the general authority of an officer or agent to contract for a corporation does not include the power to make unusual contracts.  Carney v. New York Life Insurance 162 N.Y. 453, 57 N.E. 78 (1900).  See also Business Corporation Law Sec: 624; 708(a); 908; 911.

New York is in accord with the rule established in many jurisdictions that a corporation is not liable upon a contract of suretyship or guaranty made by an officer, in the absence of evidence that the contract was within the express or implied authority of the officer, or was within his ostensible or apparent authority as established by the practice of the company (18 B Am. Jur. 2d, Corporations sec. 1551).  An officer of a corporation cannot bind the corporation to pay the debt of another by a mere promise of payment.  Bankers’ Trust Co. v. International R. Co. 207 A.D. 579, 202 N.Y.S. 561, affd 239 N.Y. 619, 147 N.E. 220 (1924).

The law does not easily imply a power in a corporate officer or agent to encumber the property of a corporation where the latter is not engaged in the business of encumbering property of the kind involved.  Unless actual or apparent authority is conferred, the officers or agents of a corporation have no authority to encumber the property of the corporation and, in the absence of ratification thereof, it would not be binding on the corporation.  It is not, as a general rule, within the apparent authority of a president of a corporation to encumber its property by executing a Note and Mortgage to secure his personal purchase of real property.

The mortgaging of corporate property generally requires the consent of the stockholders.  In the absence of such express authority corporate officers or agents do not have the power or authority to give even a mortgage on personal property where that is not within the regular and normal course of the business of the corporation.  In re Chubby’s Parkchester, Inc. 94 F Supp 701 (1951, DC N.Y.).

Corporate officers or agents have no right or authority to use, divert, or appropriate corporate property for their own individual interests or purposes.  Thus, a corporate officer has no authority to use corporate funds for payment of his own debts.  Quintal v. Kellner 264 N.Y. 32, 189 N.E. 770 (1934).  A general agent of a corporation, entrusted by the corporation with the management of its affairs, has no actual authority to appropriate the corporate property to his own use by transfer to himself directly or indirectly.  In such a case, the attempted transfer is made without actual authority, and it constitutes a conversion and passes no title to anyone.  Wen Kroy Realty Co. v. Public Nat’l Bank & Trust Co. 260 N.Y. 84, 183 N.E. 73 (1933).  G.E. Capital Mortgage Services Inc. v. Taylor 228 A.D. 2d 475, 644 N.Y.S. 2d 295 (A.D. 2nd 1996).  In Nash v. Y and T Distributors, 207 A.D. 2d 799, 616 N.Y.S. 2d 402 [2d Dept 1994], the Court stated:

Essential to the creation of apparent authority are words or conduct of the principal, communicated to a third party, that give rise to the appearance and belief that the agent possesses authority to enter into a transaction.  The agent cannot by his own acts imbue himself with apparent authority. “Rather, the existence of ‘apparent authority’ depends upon a factual showing that the third party relied upon the misrepresentation of the agent because of some misleading conduct on the part of the principal – not the agent.” (Ford v. Unity Hosp., 32 N.Y. 2d 464, 473; see, also, Restatement, Agency 2d, sec. 27.)  Moreover, a third party with whom the agent deals may rely on an appearance of authority only to the extent that such reliance is reasonable (see Wen Kroy Realty Co, v. Public Nat. Bank & Trust Co., 260 N.Y. 84, 92-93; Restatement, Agency 2d, sec. 8, Comment c; Conant, Objective Theory of Agency: Apparent Authority and the Estoppel of Apparent Ownership, 47 Neb L Rev 687, 681)” (Hallock v. State of New York, supra, at 231).

 

See also Standard Funding Corp. v. Lewitt et. al. 89 N.Y. 2d 546, 656 N.Y.S. 2d 188. (1997)  

The creation of apparent authority to enter the transactions in issue as defendant’s agent requires words or conduct of the principal--defendant--communicated to plaintiff as a third-party, which gave rise to the appearance and reasonable belief that the agent possessed authority to enter into the transactions (see Hallock v. State of New York, 64 N.Y. 2d 224, 231; see also City of Cohoes v. Kestner Engrs., 226 A.D. 2d 914;  Standard Bldrs. Supplies v. Gush, 206 A.D. 2d 720, 721; Mead v. Finger Lakes-Seneca Coop. Ins. Co., 184 A.D. 2d 952, 953).  The plaintiff failed to take even minimal steps to discover the actual scope of authority (Chelsea Natl. Bank v. Lincoln Plaza Towers Assocs., 93 A.D. 2d, 219, affd 61 N.Y. 2d 817).  An “agent cannot by his own acts imbue himself with apparent authority” (Hallock v. State of New York, supra, at 231).  See also Fleet Bank v. Consola 268 A.D. 2d 627, 701 N.Y.S. 2d 182 (A.D. 3rd 2000).

            Plaintiff attempted to show at trial defendant’s authority as a result of other transactions he undertook on behalf of ___.  At best, this evidence showed that he acted as President of ___ for its corporate purposes and benefit.  There was never a showing of his having acted on other occasions in the corporate name for his own benefit.  The corporate transactions alleged were discovered by his attorney in the course of preparation for trial and were unknown on __, 200_.  Those acts could not have misled plaintiff into believing defendant was authorized to act in such a capacity.

            Plaintiff had a clear duty to inquire into the truth of defendant’s self-serving statement as to his authority.  His failure to do so precludes him from enforcing the Note and Mortgage against ___ or its successors.


                                                            Point II

 

                        PLAINTIFF HAS NOT ESTABLISHED ANY BASIS

                        ON WHICH THE COURT MAY FIND EQUITABLE

                        ESTOPPEL.

 

            Plaintiff asserts that principles of equitable estoppel and waiver require reversal.  To be afforded the protection of equitable estoppel, a party must establish as to their adversary:

(1) Conduct which amounts to a false representation      or concealment of material facts which is calculated to convey the impression that the facts are otherwise than, and inconsistent with, those which the party subsequently attempts to assert; (2) intention, or at least expectation, that such conduct shall be acted upon by the other party; (3) knowledge, actual or constructive of the real facts.  As related to the party claiming the estoppel, [the elements] are: (1) lack of knowledge and of the means of knowledge of the truth as to the facts in question; (2) reliance upon the conduct of the party estopped; and (3) action based thereon of such a character as to change his position prejudicially” (Michaels v. Travelers Indem. Co., 257 A.D. 2d 828, 829, quoting State Bank of Albany v. Fioravanti, 70 A.D. 2d 1011, 1012-1013, affd 51 N.Y. 2d 638).

 

The record conclusively demonstrates that plaintiff’s evidentiary submissions fail to establish any of the requisite elements of equitable estoppel as they apply to the defendant.  See Brelsford v. United States Auto. Assoc., 89883 [3d Dept 2001], decided December 20, 2001.            As set forth above, certain criteria must be established for equitable estoppel to apply.  As to ___:

(1)   Conduct which amounts to a false representation or concealment of material facts:

___ had no dealings with the plaintiff and was not aware of defendant’s actions in executing the note and mortgage.  Plaintiff, who knew the other shareholders, never spoke to them concerning the transaction nor did his attorney seek any corporate resolution authorizing the execution of the documents.

(2)   Intentions or expectation that the conduct be acted upon:

The plaintiff never produced any evidence to show that ___ or its shareholders were aware of the transaction or that they were aware of any other self-dealing by defendant and approved such actions.

(3)   Knowledge of the real facts:

The plaintiff never met his burden of proof to show that ___ or its shareholders had actual or constructive knowledge of defendant’s actions in executing the note and mortgage.  In fact, the only evidence produced was to the contrary.

            As to the plaintiff:

(1)   Lack of knowledge or the means of knowledge of the truth as to the facts:

Plaintiff testified he knew the other shareholders and principals of ___ but did not consult with them in any manner to inquire if the transaction and acts of defendant were appropriate.  He was aware of who they were and was in a position to contact them – however he failed to do so.

(2)   Reliance on the Party estopped:

Since there was no testimony as to actions by the other shareholders of ___ upon which the plaintiff relied, this point fails,

Where the facts within the knowledge of a purchaser are of such a nature as in reason to put him upon inquiry and to excite the suspicion of an ordinary prudent person, and he fails to make any investigation, he will be chargeable for that knowledge which a reasonable inquiry as suggested by the facts would have revealed.  Anderson v. Blood 152 N.Y. 285, 46 N.E. 493.  See also: Miner v. Edwards 221 A.D. 2d 934,

634 N.Y.S. 2d 306 (A.D. 4th Dept 1995).

 

A reasonable inquiry by Plaintiff would have revealed to him the lack of consent of ___’s other two shareholder/directors, and he is chargeable with that knowledge.

            Plaintiff’s assertion that the mortgage in question was included in defendant’s tax return and therefore, should create an estoppel is without foundation.  ___ indicated he did not know what the entry reflected and a review of the entry provides no basis for the claim.  Plaintiff never provided proof of its claim that the listed item was the mortgage in issue and the tax return does not identify it as such.  In addition, this would have occurred after the event and was not relied upon by plaintiff so as to create an estoppel claim.  The record does not support plaintiff’s claim. 


                                                            Point III

 

THE ANSWER FILED BY ___ AND FULL AND COMPLETE DISCOVERY PROVIDED    PLAINTIFF WITH SUFFICIENT INFORMATION CONCERNING DEFENDANTS’ ALLEGATIONS AS TO DEFENDANT HAVING EXCEEDED HIS CORPORATE AUTHORITY.

           

            Plaintiff contends the defendant waived the issue of lack of authority of defendant by failing to plead same as an affirmative defense.

            First, the defendant explicitly stated in its answer that the corporation was not authorized to consummate the transaction.  The defendants’ First Affirmative Defense stated:

The Note and Mortgage referred to in the complaint were not executed as an authorized act of the corporate defendant ___ and as such they were null and void and unenforceable against these defendants.

 

            Secondly, defendants’ Third Affirmative Defense, as acknowledged in plaintiff’s Brief at page 12 stated:

                        7. The Note and Mortgage referred to in the complaint were

                             made by defendant to acknowledge and secure his own

                             debt to plaintiff.

 

                        8. Said Note and Mortgage were made without the knowledge

                            of defendant or the other shareholders of defendant ___ .

                                   

Plaintiff’s alleged “fair reading” interpretation is erroneous and lacks any credibility.  There was extensive discovery of the principals and plaintiff was fully aware of the allegations raised as to defendant’s lack of authority. 

            Plaintiff made no motion to strike defendants’ pleadings at trial and did not, in fact, raise this issue at trial.  The issue of defendant’s authority was argued at the time of the argument of Summary Judgment motions and the matter was referred to trial.  The plaintiff did not raise any alleged waiver at that time.

            In BMX Worldwide Ltd v. Coppola N.Y.C. Inc., 107 Dept 2001 decided October 25, 2001 the Court stated: 

Defendant did not waive its affirmative defense by failing to plead nonperformance of a condition precedent in its answer.  The failure of the condition precedent should come as no surprise to Plaintiff since defendant raised the same defense in response to Plaintiff’s earlier summary judgment motion.  See also: Cammarota v. Drake 285 A.D. 2d 919, 727 N.Y.S. 2d 809 (A.D. 3rd Dept 2001).

 

In this case plaintiff was not prejudiced or surprised.


                                                            CONCLUSION

                               

            The defendant has failed to show any error in the decision of the Court below and the judgment should be affirmed.

                                               

                                                                                   

                                                                                    Respectfully submitted,

 

                                                                                   

 

 

                                                                        By:       ____________________

                                                                                   

                                                                                    Attorneys for Defendants