October 11, 2016
In the Matter of a Mail Dispute Between
JAMES FREDERICK SEAMAN and HEIDI BREUNIG
P.S. Docket No. MD 16-215
APPEARANCE FOR DISPUTANT JAMES FREDERICK SEAMAN
Elizabeth A. Culley, Esq.
Andre Morris & Buttery
APPEARANCE FOR DISPUTANT HEIDI BREUNIG
Jesse L. B. Hill, Esq.
Law Office of Jesse L. B. Hill
INITIAL DECISION
This mail dispute was docketed pursuant to Postal Operations Manual (POM) § 616.21 under the procedures established at 39 C.F.R. Part 965. The disputants, James Frederick (“Fred”) Seaman and Heidi Breunig (together with Bradley A. Felger and Valerie S. DeMarco) each claim the right to receive mail addressed to Airstrike Bird Control, Inc., 1209 Park Street, Suite 301C, Paso Robles, CA 93446. The Judicial Officer directed the Paso Robles Postmaster to hold the mail addressed to Airstrike Bird Control, Inc. until this dispute is resolved.
FINDINGS OF FACT
DECISION
Mr. Seaman asserts that he is entitled to direct who shall receive ABCI’s mail because he is the CEO and 50% shareholder of ABCI. Ms. Breunig asserts that as the Secretary for ABCI she may receive the mail based on the direction of Mr. Felger (the President and CEO) and Ms. DeMarco (the Vice President).
POM § 614.1 provides that all mail addressed to an organization (including corporations) is delivered to the organization. “If disagreement arises about where any such mail should be delivered, it must be delivered according to the order of the organization’s president or equivalent official.” POM § 614.1; see also Domestic Mail Manual (DMM) § 508.1.5.1;Victor Dee and Clifford Mark Tohsonii, MD 16-142 (I.D. August 5, 2016), aff’d, (P.S.D. August 19, 2016); see also Jeffrey T. Henson and John D. Young, MD 16-19 (I.D. March 28, 2016), aff’d, (P.S.D. April 18, 2016).
The first issue in deciding this case hinges upon interpreting the POM and DMM’s meaning of “president or equivalent official.” The phrase can mean the senior official within the corporation. Alternatively, the phrase means to identify the titled “president” and then, if indeterminable the “equivalent official.” I am guided by the U.S. Court of Appeals for the District of Columbia Circuit when it was called upon to interpret the language of “foreman or equivalent official” as used in the mine safety regulations. See National Min. Ass’n v. Mine Safety and Health Admin., 116 F.3d 520, 543 (D.C. Cir. 1997). In National Mining, the D.C. Circuit looked to the intent of the regulation that notice of problems with a mine ventilation fan be given to the proper person within the organization who could act on the notice. A narrow reading would be inconsistent with the intent of the regulation’s drafters. Notice could be given to someone with a title other than “foreman” but who had the necessary authority within the organization. Id. Similarly, the intent of the POM and DMM is to deliver the mail as directed by the senior officer within the corporation.
We look to a corporation’s bylaws to determine which officer is the president or equivalent official. See Darren Rose and Wendy Del Rosa, MD 14-391 (I.D. March 11, 2015), aff’d, (P.S.D. June 1, 2015). The corporate title may not necessarily reflect which officer is the president or equivalent official for purposes of delivery of the mail. E.g., Tom Moore and Joseph Bridges, MD 07-244 (December 28, 2009) (two board factions argued that their respective officer – one the chief operating officer and the other the CEO/president – was entitled to direct delivery). In Tom Moore and Joseph Bridges we relied on a court’s guidance to indicate which party had the better claim. Id.
While often that person is titled as the president, in the present case the senior corporate officer is the CEO. ABCI’s Bylaws provide that “[t]he CEO shall, subject to the control of the Board, have general supervision, direction, and control of the business and officers of the Corporation.” (Finding 9). Also, its president operates “[s]ubject to such supervisory powers of the CEO.” (Finding 10). While the president directs day-to-day operations, the terms of the ABCI’s Bylaws provide that the CEO is more senior to the president and thus the CEO may direct the delivery of the mail, notwithstanding the president’s day-to-day authority. From ABCI’s incorporation on January 7, 2014, through July 20, 2016, Fred Seaman was ABCI’s CEO (Findings 4 and 17). As such he would have the authority to direct the delivery of the mail addressed to ABCI. The next issue in this case is whether Fred Seaman was removed as CEO on July 20, 2016.
Ms. Breunig appears to makes four arguments that Mr. Felger is the new CEO and continuing president and thus may direct the delivery of the mail. (Findings 16-18). These arguments are flawed.
First, Ms. Breunig argues that the July 14, 2016 meeting was a duly noticed meeting of the Board of Directors as required by ABCI’s Bylaws and California law. See Finding 8; see also Cal. Corp. Code § 307(a)(2) (“48 hours’ notice delivered personally or by telephone, including a voice messaging system or by electronic transmission by the corporation”). Ms. Breunig points to the July 11, 2014 email sent by Mr. Seaman as proper notice (Finding 14). Ms. Breunig further argues that even though the email does not say it is a notice of a Board of Directors meeting, it was implied by the topics listed for discussion. However, listing topics for discussion does not make this email a proper notice of a Board of Director’s meeting. Additionally, Fred Seaman states in his email: “I’m just throwing this out for discussion.” The language does not indicate that he intended a Board of Directors meeting, but rather an informal discussion. Mr. Felger’s email less than an hour before the July 14, 2016 meeting stating that it should be treated as a Board of Directors meeting also does not meet the forty-eight hour notice requirement (Findings 8 and 17). See Paul C. Thompson and John Graham, MD-68 (October 16, 1989), aff’d, (P.S.D. November 8, 1989)(the Initial Decision holds that a board election held without proper notice will not serve to replace the existing board).
Second, Ms. Breunig argues that Mr. Felger became the CEO on July 20, 2016 and may, therefore, direct delivery of the mail. This argument fails because the July 20, 2016 meeting’s legitimacy relies on the July 14 meeting being proper when no new notice was given. She also argues that notice was provided during the July 14, 2016 meeting. However, this argument is not supported by the meeting minutes of the July 14, 2016 meeting or other document in the record (Finding 17).
Third, Ms. Breunig argues that notice of the Board of Directors meeting was waived. However, Mr. Seaman did not sign the July 14, 2016 meeting minutes confirming his waiver (Finding 16). Additionally, Mr. Seaman did not attend the July 20, 2016 meeting or sign the minutes for that meeting (which contained a waiver of notice) (Finding 17).
Fourth, Ms. Breunig’s argument that a majority of the three Board members (Mr. Felger and Ms. DeMarco) could waive notice and approve Mr. Felger’s appointment as both CEO and president on July 20, 2016, assumes proper notice was given to the Board of Directors. This argument ignores the requirement for notice to the entire Board. Also, while the shareholders appointed Mr. Seaman, Mr. Felger, and Ms. DeMarco as directors on June 30, 2016, they did not amend the ABCI Bylaws to change the number of directors from four to three. Mr. Felger and Ms. DeMarco could not compose a majority, or even a quorum without Mr. Seaman’s presence (Findings 6, 7, 8). Nothing in the record shows that a majority of the stockholders approved a reduction in the number of Directors as required by the Bylaws (Finding 7).
This initial decision deals only with the delivery of the mail. It does not determine the ownership of the contents of the mail nor does it attempt to resolve any underlying disputes between the parties. If a court order subsequently directs delivery of the mail, postal regulations provide that the mail will be delivered according to such an order. POM § 616.3.
Recommendation
I recommend that the Judicial Officer issue an order to the Paso Robles Postmaster directing that all mail being held, or hereafter received, addressed to Airstrike Bird Control, Inc., 1209 Park Street, Suite 301C, Paso Robles, CA 93446 or ABCI, 1209 Park Street, Suite 301C, Paso Robles, CA 93446be delivered as directed by James F. Seaman (also known as Fred Seaman).
Peter F. Pontzer
Administrative Judge