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NORTH CAROLINA |
IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION |
| GUILFORD COUNTY |
06 CvS 4430 |
| |
|
| STEVE SAWYER, Plaintiff, |
|
| v. |
COMPLAINT |
| MARKET AMERICA, INC., Defendant. |
|
| |
|
|
THE PLAINTIFF, complaining of the defendant, avers: |
| GENERAL ALLEGATIONS |
| 1. The plaintiff Steve Sawyer ("Sawyer") is a citizen and resident of Aloha, Oregon. |
| 2. Upon information and belief, Market America, Inc. ("Market America") is a corporation,
organized and existing under the laws of the State of North Carolina, with a principal place
of business in Greensboro, Guilford County, North Carolina. |
| 3. During the period December 1, 2004 through January, 2006, Sawyer worked as Internet
Sales Manager for Market America. Pursuant to agreement, Market America
provided written notice of termination of Sawyer's employment, effective as of the end of February, 2006, and
waived work by Sawyer during February, 2006. |
| 4. Market America agreed to compensate Sawyer for his services at the rate of $4,166.67
per month, plus an honorarium fee for specific speaking engagements mutually agreed upon by
the parties, and certain expense reimbursements. Additionally, Market America agreed to pay
Sawyer a $10,000 bonus for causing Market America Internet sales to reach an approved
Conservative Goal of $4,687,732 and an additional $15,000 bonus for causing Market America
Internet sales to reach an approved Aggressive Goal of $5,231,844 for calendar year 2005. |
| 5. Sawyer remained under contract and performed work for Market America as Internet Sales
Manager for the entire year for calendar year 2005. |
| 6. Market America's Internet sales for 2005 exceeded the approved Aggressive Goal of
$5,231,844. |
| 7. Sawyer met prescribed performance objectives and is entitled to bonuses totaling $25,000
($10,000 for achieving Conservative Goal and $15,000 for achieving Aggressive Goal) for work he
performed in calendar year 2005. |
| 8. Although Sawyer worked for and provided services to Market America in January, 2006,
Market America has not made payment to Sawyer in the sum of $4,166.67 for these
services. |
| 9. Although Sawyer was ready, willing and able to work for Market America through
February, 2006, Market America gave notice and waived that obligation, in writing. Sawyer has
invoiced Market America for February, 2006, in the agreed upon sum for $4,166.67. Upon
information and belief, Sawyer believes that Market America will not honor its obligation to
pay Sawyer for work performed in February, 2006. |
| FIRST CLAIM FOR RELIEF |
| (Breach of Contract) |
| 10. The plaintiff hereby incorporates by reference all of the allegations set forth in
paragraphs 1 through 9 of this Complaint as if herein fully repeated by reference thereto. |
| 11. Market America's failure and refusal to pay Sawyer his earned bonuses for Internet
sales goals achieved for calendar year 2005 constitutes a breach of contract, entitling
Sawyer to have and recover from Market America $25,000, plus interest from January 10, 2006
until paid. |
| 12. Market America's failure and refusal to pay Sawyer the agreed upon figure of
$4,166.67 for work performed during January, 2006 constitutes a breach of contract, entitling Sawyer to
have and recover from Market America the sum of $4,166.67, together with interest from
February 10, 2006 until paid. |
| 13. In the event Market America does not pay to Sawyer the agreed upon sum of $4,166.67
for February, 2006, such failure will constitute a breach of contract, entitling Sawyer to
have and recover from Market America the sum of $4,166.67, together with interest from
March 10, 2006 until paid. |
| SECOND CLAIM FOR RELIEF |
| (Violation of the Wage Payment Provisions of the North Carolina Wage and Hour Act) |
| 14. The plaintiff hereby incorporates by reference all of the allegations set forth in
paragraphs 1 through 13 of this Complaint as if herein fully repeated by reference thereto. |
| 15. Market America "suffered or permitted" Sawyer to work during the period December 1,
2004 through January, 2006, as that phrase is used in § 95-25.2(3) of the North Carolina General Statutes.
Market America waived, in writing, work by Sawyer during February, 2006. |
| 16. Market America employed Sawyer during the period December 1, 2004 through January,
2006, within the meaning of "employ" as that term is defined in § 95-25.2(3) of the North Carolina General
Statutes. |
| 17. During the period December 1, 2004 through February, 2006, Sawyer was an "employee" of
Market America within the meaning of that term as defined in § 95-25.2(4) of the North
Carolina General Statutes. |
| 18. Market America was the "employer" of Sawyer during the period December 1, 2004
through February, 2006 within the meaning of that term as defined in § 95-25.2(5) of the North Carolina
General Statutes. |
| 19. The aforesaid bonuses of $25,000 and monthly compensation of $4,166.67 owed by Market
America to Sawyer constitute "wages" within the meaning that term as defined in § 95-25.2(16}
of the North Carolina General Statutes. |
| 20. Market America's failure and refusal to pay to Sawyer the aforesaid bonuses of
$25,000 and monthly compensation of $4,166.67 constitutes a violation of § 95-25.7 of the North Carolina
General Statutes. |
| 21. Pursuant to the provisions of § 95-25.22 of the North Carolina General Statutes, Sawyer
is entitled to have and recover from the defendant unpaid but accrued bonuses in the amount of
$25,000, plus $4,166.67 for work performed during January, 2006, and $4,166.67 for February,
together with interest, liquidated damages, and attorneys' fees. |
| WHEREFORE, plaintiff prays to have and recover of the defendant the sum of $25,000 in earned
but unpaid bonuses together with interest at the legal rate from January 10, 2006 until paid,
$4,166.67 for work performed in January, 2006, together with interest at the legal rate from
February 10, 2006 until paid, and $4,166.67 for February, 2006, together with interest at the legal
rate from March 10, 2006 until paid; that the plaintiff have and recover from the defendant liquidated
damages equal to the aforesaid principal amounts; that the costs of this action, including a reasonable
attorney's fee for counsel for the plaintiff, be taxed against the defendant; and that the Court grant
to the plaintiff such other and further relief as to the Court may seem just and proper. |
| This the 3_ day of March, 2006. |
| Kenneth R. Keller |
| Attorney for Plaintiff |
| OF COUNSEL: |
| CARRUTHERS & ROTH, P.A. |
| P.O. Box 540 |
| Greensboro, NC 27402 |
| Telephone: (336) 379-8651 |
| DEMAND FOR JURY TRIAL |
| The plaintiff hereby demands a trial by jury on all of the issues raised by the pleadings in this action. |
|
| Lawsuit Update: |
On Monday, April 23, 2007, the trial court advised Steve Sawyer's lawyer and Market America's legal team that the trial would commence at 1:30 p.m. on Tuesday, April 24th. Pending motions in the case were to be heard first and then the jury would be picked. On Tuesday the Judge heard arguments on the preliminary motions. One of the motions heard was Market America’s motion for a partial summary judgment which, basically, was a request that Steve Sawyer’s 2nd claim against Market America be dismissed. This claim alleged that the services that Steve’s performed under his contract with Market America constituted an employee – employer relationship under the North Carolina Wage and Hour Act. |
| Market America’s motion claimed that this cause of action was not available to Steve as he was not a resident of the State of North Carolina. Market America’s legal team argued that the provisions of the North Carolina Wage and Hour Act were only available to North Carolina residents and Steve was a resident of the State of Oregon during the time he performed under his contract with Market America. The trial judge was advised that, while the North Carolina Wage and Hour Act was adopted in 1937, this issue had never been decided by the appellate courts of North Carolina. After hearing arguments pro and con from the attorneys, the trial court decided to grant Market America’s motion for partial summary judgment on this claim. |
| The judge advised both sides that the contract claim could either proceed to trial the next day or be postponed until Steve’s lawyer could appeal the court’s ruling on the residency issue. If the appellate courts overruled the judge’s decision then both causes of action could be tried when the case was ultimately heard. If the appellate courts affirmed the judge’s ruling then just the contract claim would be heard. This would, depending on the appellate court’s decision, save having two trials. On Wednesday morning Steve’s lawyer advised the court that Steve had decided to appeal the court’s ruling and would like the case postponed until the appellate courts could rule on this issue, which had never been decided by the North Carolina appellate courts. Market America’s legal team offered no objection with this decision and the court postponed the trial until the appeal could be heard. |
| Steve is hopeful that the North Carolina appellate courts rule that the provisions of the North Carolina Wage and Hour Act are available to non-residents so that this claim can be heard on its merits. Steve would like you to know that, if all of the North Carolina trial judges are like Judge John Craig, North Carolina can be very proud of its trial bench. He has, and exhibited, all of the fine traits that the public hopes to find in a member of the bench. |
| Steve, who is extremely disgruntled, will keep you posted as this case progresses through the courts. |
|
| Lawsuit Update: |
I thought that I should give you an update on what has been occurring in my case against Market America. |
As you may recall I have two causes of action in my lawsuit against Market America. One cause is based
in Contract and the other cause is based on employment under the North Carolina Wage and Hour Act. |
My contract with Market America had both a Choice of Forum and Choice of Laws provision that required any
dispute with Market America to be tried in Guilford County, North Carolina and that the laws of North Carolina
would govern the terms of the contract. |
I have a factual dispute as to whether or not I was an independent contractor under North Carolina law or
whether the facts show that I was an employee. If the Court, after hearing the evidence, determined that I was
an employee then, under the North Carolina Wage and Hour act I would be entitled to double damages and attorney fees.
If it is determined that I was an independent contractor then I would only have the contract cause of action for my
bonuses and 2 months of pay, the total of which could be $33,000.00. |
Market America had filed a summary judgment motion against my Complaint asking the Court to rule as a matter
of law that (1) the North Carolina Wage and Hour act was not available to me since I was not a resident of North Carolina;
(2) Because the North Carolina Wage and Hour Act was not available to me as a non resident it didn't make any difference
that my contract had a choice of laws provision that stated that North Carolina laws governed our contract.; (3) that
as a matter of law I was an independent contractor and not an employee. |
When we appeared for a jury trial in Superior Court of Guilford County on April 24, 2007, Superior Court Judge
John O. Craig, III, first ruled on Market America's summary judgment motions. He ruled that the North Carolina Wage
and Hour Act wasn't available to me as I was not a resident of North Carolina and even though my contract had the choice
of laws provision this still did not give me the right to utilize the North Carolina Wage and Hours act because I was a
non resident. |
Judge Craig chose not to rule on the issue of Employee v Independent Contractor as his first two rulings disposed
of my claims under the wage and hour act. |
The two issues that were before Judge Craig, and on which he ruled, had never before been decided by the Appellate
Courts of North Carolina. I appealed Judge Craig's Order, entered in Superior Court on May 9, 2007, to the North Carolina
Court of Appeals. |
The case was heard before the North Carolina Court of Appeals on April 28, 2008. The North Carolina Court of Appeals
affirmed Judge Craig's, decision on June 3, 2008. I am in the process of asking the North Carolina Supreme Court of review
and reverse the Appellate Courts decision. I am hopeful that Supreme Court will take the case to review since it is such an
important issue for employers and employees and has such a profound impact on North Carolina employment law. It is also an
issue that will undoubtedly be discussed, pro and con, in Law Review articles in one or more of the 5 law schools in
North Carolina. |
Irrespective of what the Supreme Court of North Carolina does with the issues that have been decided by the Court of
Appeals my first cause of action, based on contract, as to whether or not I am entitled to (1) a $15,000.00 bonus; (2) an
additional $10,000.00 bonus, and: (3) unpaid salary for 2 months, has yet to be decided by a jury. |
When this matter will ultimately be concluded is difficult to predict but knowing that each side is convinced of their
respective positions and knowing that the combined attorney fees for both sides presently exceed $100,000.00, I am sure that
it will not be concluded until both sides have exhausted all of their legal remedies. Two or three more years for the legal
issues to be resolved would be my guesstimate. |
|
| Lawsuit Update: January 2009 |
On December 11, 2008, the North Carolina Supreme Court of North Carolina in the case of Steve Sawyer v Market America, Inc.
entered the following order which denied Sawyer's request that they review the decision of the North Carolina Court of Appeals. |
| SUPREME COURT OF NORTH CAROLINA |
| ******************************************** |
| (Sawyer v Market America, Inc.) |
| STEVE SAWYER |
| MARKET AMERICA, INC. |
| From NC Court of Appeals |
| (07-1257) |
| From Guilford |
| (06CVS4430) |
| ******************************************** |
| ORDER |
| Upon consideration of the petition filed on the 7th day of July 2008 by Plaintiff in this
matter for discretionary review of the decision of the North Carolina Court of Appeals pursuant to G.S. 7A-31, the
following order was entered and is hereby certified to the North Carolina Court of Appeals: "Denied by order of the Court
in conference, this the 11th day of December 2008. |
| s/ Hudson, J. |
| For the Court" |
|
|
Because Steve has exhausted his remedies in North Carolina asking the North Carolina Courts to grant him his rights for relief
under the North Carolina Wage and Hour Act Steve Sawyer had his Oregon attorneys file the following lawsuit in the State of Oregon, again
entitled Steve Sawyer vs Market America. That Complaint reads as follows: |
CIRCUIT COURT OF OREGON |
|
| COUNTY OF MULTNOMAH |
0812-18343 |
| |
|
| STEVE SAWYER, |
Plaintiff, |
| v. |
|
| MARKET AMERICA, INC., |
Defendant, |
| a foreign corporation |
|
| COMPLAINT |
|
| (Wage Claim) |
|
| Claim More than $10,000 |
|
| SUBJECT TO MANDATORY ARBITRATION |
|
| JURY TRIAL DEMANDED |
|
|
Comes now the THE PLAINTIFF, Steve Sawyer, by and through his attorney, and states and alleges as follows: |
| FIRST CLAIM FOR RELIEF |
| (Wage Claim, Statutory Penalty Wages) |
| 1. At all times material herein, Plaintiff was an Oregon resident. |
| 2. At all times material herein, the Defendant (Market America) was a Foreign Corporation,
doing business in Oregon. |
| 3. At all times material herein, Plaintiff was employed by Defendant (Market America). |
| 4. On March 1, 2006, Defendant (Market America) terminated Plaintiff's employment. |
| 5. After Plaintiff's employment ended, Defendant (Market America) failed to make payment of all
of Plaintiff's earned wages, when required by O.R.S. 652.140. |
| 6. Defendant (Market America) failed to pay Plaintiff's bonuses in an amount to be determined at
trial but not less than $25,000. |
| 7. Defendant (Market America) also failed to pay regular wages in an amount to be determined at
trial but not less than $8,333.34. |
| 8. On or about December 23, 2008, Plaintiff sent written notice to Defendant (Market America) of
Defendant's (Market America) nonpayment of Plaintiff's wages. |
| 9. Plaintiff also noticed Defendant (Market America) multiple times in writing, of its non-payment
before, and specifically on March 3, 2006. |
| 10. Defendant's (Market America) failure to make payment of Plaintiff's wages when due was wilful
and said failure continued for a period exceeding 30 days after Plaintiff's wages were due. |
| 11. Defendant (Market America) failed to pay Plaintiff's wages as set out above on March 3, 2006
and those wages remain due and owing. |
| 12. Because of Defendant's (Market America) wilful failure to immediately make payment when due,
Plaintiff is due statutory penalty wages, pursuant to O.R.S. 652.150, for the continuation of Plaintiff's wages for 30 days. |
| 13. Plaintiff has been required to bring this action to recover wage earnings due and owing at the time of termination,
and statutory wages as provided by O.R.S. 652.150. |
| 14. On or about December 23, 2008, Plaintiff's attorney gave written notice of Plaintiff's wage claim to the Defendant
(Market America) prior to filing this action. |
| 15. Because of Defendant's (Market America) failure to pay Plaintiff's wages within 48 hours after they
were due, Plaintiff is entitled to recover costs, disbursements, and reasonable attorney fees, pursuant to O.R.S. 652.200(2). |
| 16. Plaintiff seeks as damages, unpaid wages, statutory wages pursuant to O.R.S. 652.150, and costs, disbursements and
attorney fees, pursuant to O.R.S. 652.200(2). |
| WHEREFORE; Plaintiff demands judgment against the Defendant (Market America): |
| UPON PLAINTIFF'S CLAIM FOR RELIEF FOR VIOLATION OF PAYMENT OF WAGES: |
| 1) Unpaid wages in an amount as determined. |
| 2) Statutory penalties pursuant to O.R.S. 652.150. |
| 3) Costs and disbursements, pre- and post- judgment interest in the amount of 9% per annum, and attorney fees incurred herein,
pursuant to O.R.S. 652.200(2). |
| DATED: December 26, 2008. |
| DAVID A. SCHUCK, OSB 993564 |
| Attorney for Plaintiff |
|
Market America hired Stacey E. Mark of the Oregon law firm of AterWynne, LLP to defend against this lawsuit
and she has demanded that Steve's lawyers dismiss this lawsuit against Market America. Market America has filed a motion for emergency injunctive
relief in the case of Steve Sawyer v Market America, Guilford County Superior Court, Case No. 06 CVS 4430 and it is set out herein. |
NORTH CAROLINA |
IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION |
| GUILFORD COUNTY |
06 CvS 4430 |
| |
|
| STEVE SAWYER, Plaintiff, |
|
| v. |
COMPLAINT |
| MARKET AMERICA, INC., Defendant. |
|
| DEFENDANT'S MOTION FOR EMERGENCY INJUNCTIVE RELIEF |
|
NOW COMES Defendant Market America, Inc. ("Market America"), by and through its undersigned counsel,
and pursuant to N.C.G.S. § 1-485(2), Rule 65 of the North Carolina Rules of Civil Procedure, and the inherent power of the Court,
moves for emergency injunctive relief enjoining Plaintiff from pursuing any claims in a later-filed action in Oregon state court which is
duplicative of this action and which violates his contractual agreement designating this Court as the forum for any dispute with Market America. |
In support of this motion, Market America states unto the Court the following:. |
| PROCEDURAL HISTORY |
| 1. This action was filed on March 3, 2006 by Plaintiff Steve Sawyer, who alleged that he was "a citizen and resident of Aloha, Oregon." (Cplt. ¶ 1.)
The Complaint asserted two causes of action: (1) for breach of contract (id. at ¶¶ 10-13) and (2) for violation of the wage payment provisions of the
North Carolina Wage & Hour Act, N.C.G.S. § 95-25.1, et seq. (id. at ¶¶ 14-21.) |
| 2. After substantial discovery, Market America filed a Motion for Partial Summary Judgment on April 12, 2007. In that motion,
Market America sought summary judgment with respect to Sawyer's second claim under the North Carolina Wage & Hour Act. Pertinent to this Motion, the
contract at issue, an Independent Contractor Agreement between Sawyer and Market America (filed as Exhibit 5 in the Notice of Filing accompanying the
Motion for Partial Summary Judgment and attached hereto as Exhibit A), contains a section 7 entitled "Forum Selection" which provides that "any claim or conflict
arising out of this agreement shall be adjudicated in Guilford County, North Carolina." |
| 3. After a hearing, this Court (The Honorable John O. Craig, III presiding) granted Market America's summary judgment motion with respect
to the Wage & Hour Act claim. That Order was entered on May 9, 2007. Judge Craig also certified that ruling for immediate appeal pursuant to Rule 54(b) of the North
Carolina Rules of Civil Procedure. |
| 4. After oral argument heard in the Court of Appeals on April 28, 2008, the Court of Appeals affirmed summary judgment in Market America's
favor on June 3, 2008. Sawyer v. Market America, Inc., 661 S.E.2d 750 (N.C.App. 2008). |
| 5. Thereafter, Sawyer timely filed a Petition for Discretionary Review with the North Carolina Supreme Court. That Petition was denied on December 11, 2008,
and, pursuant to Rule 32(b) of the North Carolina Rules of Appellate Procedure, the appellate court's mandate to this Court issued December 31, 2008. The action, therefore,
is ready for trial on Sawyer's sole remaining claim for breach of contract. |
| SAWYER'S ATTACK ON THIS COURT'S JURISDICTION |
| 6. As noted above, the contract at issue herein contains a forum selection clause which provides that any dispute between the parties shall be heard in this Court.
(Ex. A, at § 7.) |
| 7. Notwithstanding that provision and this earlier-filed action, Sawyer, on December 26, 2008, filed an action against Market America in the
Circuit Court of Oregon, Multnomah County, styled Steve Sawyer v. Market America, Inc., No. 812-18343 (the "Oregon Action"). (The Complaint in the
Oregon Action is attached as Exhibit B.) It purports to state a claim under the Oregon Wage Act, O.R.S. 652.140, et seq. |
| 8. As a result of the filing of the Oregon Action, Market America has been forced to consult with a lawyer in Oregon who, on January 6, 2009,
sent a letter to Sawyer's Oregon lawyer demanding dismissal of the Complaint by January 9, 2009, on the grounds, inter alia, of the pendency of this action and the forum
selection clause. (A copy of that letter is attached hereto as Exhibit C.) |
| 9. In addition, on January 9, 2009, Market America's counsel sent an email message to Sawyer's counsel of record in North Carolina making him
aware of the newly-filed Oregon Action and attaching a copy of the correspondence from Market America's Oregon counsel to Sawyer's Oregon counsel. |
| 10. Despite those communications with Sawyer's counsel, the Oregon Action has not been dismissed and Market America now finds itself in a position
where it will have to expend more in time and resources seeking to defend against the newly-filed Oregon Action. |
| LEGAL ARGUMENT |
| 11. This Court has jurisdiction over Sawyer. While Sawyer is not a resident of North Carolina, he has filed a Complaint and sought relief from the Superior Court of
Guilford County, North Carolina, and thus has consented to its jurisdiction over him and has availed himself of its processes and procedures (as well as those of the North Carolina
appellate courts) for nearly three years. At all times, he has been a willing participant in this action and has thereby submitted himself to the jurisdiction of this Court. |
| 12. The Oregon Action was filed in December, 2008, nearly three years after Sawyer filed the Complaint in, and consented to the jurisdiction of, the Superior Court of
Guilford County. |
| 13. Depositions have been taken in this action of a number of individuals, generating a number of volumes of testimony and numerous exhibits. Numerous pleadings,
motions, or other filings have been made in this Court and in the North Carolina appellate courts. |
| 14. The Oregon Action is duplicative of and serves no useful purpose not already being served in this action inasmuch as the issues pending in the Oregon Action are
also issues that could have been before this Court and, in fact, were required to be brought here pursuant to the forum selection clause in the parties' Agreement. The Oregon Action
multiplies litigation, duplicate issues of fact and law, and results in an unnecessary and wasteful use of Court resources and litigant resources. The continued prosecution of the
Oregon Action threatens additionally to delay the orderly disposition of this action. |
| 15. Equity demands that Sawyer be enjoined from further prosecuting of the Oregon Action, and it is within the inherent and statutory power of this Court to enter this
Order to protect the rights and interests of all of the parties involved in this action. |
| 16. The injunction sought is consistent with the law of the State of North Carolina and necessary to avoid the unnecessary expenditure of time, resources, and costs
resulting from the simultaneous maintenance of this action and the Oregon Action. See Staton v. Russell, 151 N.C.App. 1, 14, 565 S.E.2d 103, 111 (2002) (affirming injunction
against non-North Carolina plaintiffs from prosecuting later-filed action in Florida concerning the same subject matter); Wallace Butts Insurance Agency, Inc. v. Runge,
68 N.C.App. 196, 202, 314 S.E.2d 293, 297 (1984) (enjoining party which brought suit in North Carolina from prosecuting an action in South Carolina concerning "the same subject matter"). |
| 17. The issuance of the injunction sought will prevent any further depletion of this Court's or any other court's time and resources. |
| 18. The injunction sought is justified under the inherent power of the Court, N.C.G.S. § 1-485(2), and Rule 65 of the Rules of Civil Procedure, in that there is a reasonable
apprehension of irreparable loss of time and financial resources unless injunctive relief is granted and such relief is necessary to protect the rights of Market America in this action. |
| WHEREFORE, Market America respectfully requests that this Court enter an injunction enjoining Plantiff from pursuing his claims in Steve Sawyer v.
Market America, Inc., No. 812-18343 (Cir. Ct., Multnomah Ct'y, Oregon). |
| PLEASE TAKE NOTICE that Market America will seek a hearing on this Motion for Emergency Injunctive Relief on January 22, 2009 or as soon thereafter as the matter may be heard. |
| This the 21st day of January, 2008. |
| CERTIFICATE OF SERVICE |
| The undersigned attorney hereby certifies that on the 21st day of January, 2009, he caused the foregoing document to be served upon the attorney shown below by email and by first-class mail addressed to said attorney: |
| Kenneth R. Keller, Esq. |
| Carruthers & Roth, P.A. |
| 235 N. Edgeworth Street |
| Greensboro, NC 27401 |
| krk@crlaw.com |
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