Evans v. Pearson Enterprises, Inc.

Summary

The Sixth Circuit affirmed dismissal of Jane Evans's claims arising from alleged fiduciary breaches, shareholder oppression, fraud, misrepresentation, and related conduct involving family trusts and corporate transactions. The court held that the probate exception did not bar federal jurisdiction over the breach-of-revocable-trust claim, but collateral estoppel and pleading deficiencies independently supported dismissal, and the district court did not abuse its discretion in denying leave to amend.

Holdings

1. The probate exception did not deprive the federal district court of jurisdiction over Evans's in personam claim concerning her revocable inter vivos trust because the claim did not interfere with probate proceedings, require general jurisdiction over probate, or require federal control over property in state custody.
2. Although the district court had jurisdiction over the revocable-trust claim, dismissal was proper because collateral estoppel barred Evans from relitigating fraudulent concealment and the applicable statute-of-limitations issues.
3. The shareholder-oppression claims concerning the 1993 and 1996 transactions were barred by Michigan's six-year statute of limitations because Evans did not plead fraudulent concealment with the particularity required by Rule 9(b), and collateral estoppel independently barred reliance on fraudulent concealment.
4. The shareholder-oppression claim concerning the 1998 transaction failed because collateral estoppel barred Evans from asserting the factual allegations on which the claim depended.
5. The fraud claims concerning the 1993 and 1996 transactions were barred by the statute of limitations because Evans failed to plead fraudulent concealment with particularity. The fraud claim concerning the 1998 transaction failed because Evans did not plead detrimental reliance with particularity.
6. The district court did not abuse its discretion in denying Evans's requests for leave to amend because the first request failed to state grounds with particularity and the later requests were not clearly presented as distinct motions.

Questions Presented

1. Whether the federal probate exception deprived the district court of jurisdiction over Evans's claim for breach of her revocable inter vivos trust.
2. Whether collateral estoppel barred Evans's breach-of-trust claim by preventing relitigation of fraudulent concealment and related limitations issues.
3. Whether Evans's shareholder-oppression claims concerning the 1993 and 1996 transactions were barred by Michigan's statute of limitations and could be saved by fraudulent concealment.
4. Whether collateral estoppel barred the shareholder-oppression claim concerning the 1998 transaction.
5. Whether Evans's fraud claims were barred by the statute of limitations or failed for insufficient pleading of reliance.
6. Whether the district court properly denied Evans's requests for leave to amend.

Disposition

affirmed