Nos. 15-3872(L), 15-3878 In the United States Court of ... · Jo Ann Howard & Associates, et al.,...

Nos. 15-3872(L), 15-3878

In the United States Court of Appeals for the Eighth Circuit

Jo Ann Howard & Associates, et al., Appellees/Cross-Appellants

v.

National City Bank; PNC Bank, N.A., Appellants/Cross-Appellees

On Appeal from the United States District Court For the Eastern District of Missouri (No. 4:09-CV-01252)

(The Honorable E. Richard Webber, J.)

BRIEF OF AMICI CURIAE AMERICAN BANKERS ASSOCIATION AND MISSOURI BANKERS ASSOCIATION IN SUPPORT OF APPELLANTS

NCB AND PNC URGING REVERSAL

Susan Ford Robertson #35932 J. Zachary Bickel #58731 The Robertson Law Group, LLC 1903 Wyandotte, Suite 200 Kansas City, MO 65108 816-221-7010 (phone) 816-221-7015 (fax)

Appellate Case: 15-3872 Page: 1 Date Filed: 03/15/2016 Entry ID: 4378194 Appellate Case: 15-3878 Page: 1 Date Filed: 03/28/2016 Entry ID: 4382196

CORPORATE DISCLOSURE STATEMENT

American Bankers Association ("ABA") is non-profit organization with

no parent company and no stock.

Missouri Bankers Association ("MBA") is a non-profit organization with

no parent company and no stock.

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TABLE OF CONTENTS TABLE OF AUTHORITIES .................................................................. 4 INTEREST OF AMICI CURIAE ........................................................... 6 SUMMARY OF THE ARGUMENT ..................................................... 8 ARGUMENT .......................................................................................... 9 I. The scope of duties and responsibilities of trustees are based in trust law ........................................................................ 9 II. Banks and corporate trustees relied upon statutes governing pre-need contracts in deciding whether to accept and how to price trust business ...................................................................... 13 III. Damages for breach of a trustee’s duties are tied to the value of the property the trustee is entitled to protect .................... 18 CONCLUSION ....................................................................................... 22 CERTIFICATE OF COMPLIANCE ...................................................... 23 CERTIFICATE OF SERVICE ............................................................... 24

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TABLE OF AUTHORITIES

FEDERAL CASES

Packard v. Provident Nat’l Bank, 994 F.2d 1039 (3rd Cir. 1993) .......................................... 10, 11

STATE CASES

Barnett v. Rogers, 400 S.W.3d 38 (Mo.App. 2013) ............... 18

Covey v. Pierce, 82 S.W.2d 592 (Mo.App. 1935) .................. 10

Davis v. U.S. Bank Nat’l Assoc.,

243 S.W.3d 425 (Mo.App. 2008) ............................................. 16

Masterson v. Plummer, 343 S.W.2d 352 (Mo.App. 1961) ........ 9

Novoletsky v. Metro. Life Ins., 49 F. Supp. 123 (D. Me. 2014) ................................................. 11 Parker v. Pine, 617 S.W.2d 536 (Mo.App. 1981) .................. 18

Rouner v. Wise, 446 S.W.3d 242 (Mo. banc 2014) .................... 9

Witmer v. Blair, 588 S.W.2d 222 (Mo.App. 1979) .................. 10

STATUTES AND RULES

Section 362.011 R.S.Mo. ............................................................ 9

Section 362.425 R.S.Mo. ............................................................ 9

Section 436.005-.520 R.S.Mo. .......................................... 13, 14

Section 436.005 R.S.Mo ........................................................... 13

Section 436.031(2) R.S.Mo. ................................................14-17

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Section 436.045 R.S.Mo. .......................................................... 14

Section 436.440-.520 R.S.Mo. ........................................... 13, 16

Section 456.10-1002 R.S.Mo. .................................................. 18

Section 456.8-.805 R.S.Mo. ..................................................... 18

Section 362.011 R.S.Mo. ............................................................ 9

Section 362.425 ......................................................................... 9

MISCELLANEOUS

Restatement (Second) of Trusts § 2 (1959) ............................... 9

Dictionary of Banking Terms (2nd Ed. 1993) .......... 9-11, 15, 16

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INTEREST OF AMICI CURIAE

American Bankers Association ("ABA") is the principal national trade

association of the financial services industry in the United States. Founded in

1875, the ABA is the voice for the nation's $13 trillion banking industry and its

over 1 million employees. ABA members provide banking services in each of the

fifty states and the District of Columbia. ABA membership includes all sizes and

types of financial institutions, including very large and very small banking

operations.

Missouri Bankers Association ("MBA"), founded in 1891, is a statewide

association advocating for and representing more than 300 state and federally

chartered banks located in Missouri. MBA banks and trust companies employ

more than 30,000 people in Missouri. The MBA maintains an interest in

promoting laws and policies that preserve a vibrant, free-market economy, and that

promote safe, sound and affordable banking services for the benefit of our

communities and the public.

Many of the ABA and MBA members, both federally and state chartered

banks, have been granted trust powers, or have been federally or state chartered

with only trust powers to serve the public by providing trust services. Banks and

trust companies are federally or state supervised and subject to regular

examination. In Missouri (and in many states) only a state or federally chartered

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trust company may hold itself out to the public as a trust company and serve as a

corporate trustee and use the words “trust company” in a corporate name. See,

Sections 362.425 and 362.011, Revised Statutes of Missouri.

The Amici have a strong interest in this case. Corporate trust services are an

important part of bank and trust services to the public. Missouri and other state

and federal courts have historically interpreted a corporate trustee’s duties and

responsibilities as defined by the trust agreement and by the common and statutory

law of trusts. Claims of a trustee’s breach of duties have been handled as matters

of equity tried to the court. The district court permitted plaintiffs to proceed to a

jury under a tort claim. Tort claims combined with vicarious liability for the

actions of a trust grantor and beneficiary introduce new legal risks to a trust

company’s operations. If risk cannot be reasonably quantified, then services will

be withdrawn or not be offered at all.

No party’s counsel authored this brief in whole or in part. No party or

party’s counsel contributed money that was intended to fund preparing or

submitting the brief. No person, other than the amici curiae, its members, or its

counsel, contributed money that was intended to fund preparing or submitting the

brief.

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SUMMARY OF THE ARGUMENT

Historically, state and federal courts have interpreted a corporate trustee’s

duties and responsibilities as defined by the trust agreement and by the common

and statutory law of trusts. Claims of a trustee’s breach of duties have been

handled as matters of equity tried to the court. Damages for breach of a trustee’s

duties have been tied to the value of the property the trustee is entrusted to protect.

The district court permitted plaintiffs to proceed to a jury under tort theories of

liability and characterization of damages. Permitting tort claims and tort-based

damages against corporate trustees is unprecedented.

Banks and corporate trustees have relied upon statutes governing pre-need

contracts in deciding whether to accept and how to price trust business. Corporate

trustee services differ depending on whether the pre-need seller used an

investment advisor. By statute, if a pre-need seller used an investment advisor, the

corporate trustee was relieved of duties in managing the investment and for

liability for investment decisions. The district court disregarded established trust

law and if its ruling is left undisturbed, the consequences are devastating on the

ability of banks and trust companies to manage, price or offer corporate trust

services. The Amici urge this Court to reverse the district court’s judgment.

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ARGUMENT

I. THE SCOPE OF DUTIES AND RESPONSIBILITIES OF CORPORATE TRUSTEES ARE BASED IN TRUST LAW. In Missouri, a corporate trustee’s duties and responsibilities are defined by

the trust agreement and by the common and statutory law of trusts. No Missouri

case has ever called this principle into the slightest doubt. “In simple terms, a

trust…may be defined as ‘a fiduciary relationship with respect to property,

subjecting the person by whom the title to the property is held to equitable duties

to deal with the property for the benefit of another person, which arises as a result

of a manifestation of an intention to create it.’” Rouner v. Wise, 446 S.W.3d 242,

251 (Mo. banc 2014), quoting Masterson v. Plummer, 343 S.W.2d 352, 355

(Mo.App. 1961) (quoting Restatement (Second) of Trusts § 2 (1959)).

Banks and trust companies offer important services to the public, including

serving as corporate trustees. These services are subject to federal and state

supervision and regular examination. Only a federal or state chartered trust

company may offer services as a corporate trustee. Section 362.425 and Section

362.011 R.S.Mo. A corporate “trust department” has been defined as a trust

company or the trust department of a bank with trust powers engaging in the

management of trust account assets for personal trust, employee benefit trusts, and

corporate accounts and agency services for trust clients. Trust Department,

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Dictionary of Banking Terms, (2nd Ed. 1993). Smaller trusts are managed

commonly as commingled funds or common account trusts, since it proves

uneconomical to manage them separately. Id. Bank trust departments also settle

estates for individuals and act as transfer agents for corporations. Trust account

funds are managed separately from other assets managed by the bank. Id. (See,

also the definition of “trust company.”)

A. Courts do not apply tort law concepts to a trust beneficiary’s claim of breach of trustee’s duties.

To date, with the exception of this case, no Missouri court has ever applied

tort law concepts to a trust beneficiary’s claim of a breach of a trustee’s duties.

Instead, Missouri courts have consistently treated any alleged violation of a

trustee’s duties, even if they are asserted to have occurred negligently, as a “breach

of trust” addressed by application of principles of equity. Witmer v. Blair, 588

S.W.2d 222, 224 (Mo.App. 1979) (a trustee’s breach of duties is still considered a

“breach of trust” even if alleged to have occurred negligently); Covey v. Pierce, 82

S.W.2d 592, 598 (Mo.App. 1935) (a trustee’s violation of duties, whether

negligent or fraudulent, is a breach of duties of trust arising from equity).

Federal cases are consistent in their treatment of allegations a trustee’s

breach of duties to be equitable and handled through application of trust law. See

Packard v. Provident Nat’l Bank, 994 F.2d 1039, 1047 (3rd Cir. 1993) (the court

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recognizing the law of trusts is different from the law of torts); Novoletsky v.

Metro. Life Ins., 49 F. Supp. 123, 150-51 (D. Me. 2014) (negligence claim

dismissed because the trustee’s duties arose out of the owed fiduciary relationship

and did not arise from a general tort duty of reasonable case).

However, ignoring state and federal precedent, the district court permitted

what was an equitable claim against the corporate trustee that should have been

submitted to the court under trust law to, instead be submitted to the jury as a

negligence claim under general tort law. If left undisturbed by this Court, the

district court’s judgment will have devastating consequences on the ability of

banks and trust companies to offer corporate trustee services.

B. Permitting tort claims against corporate trustees is unprecedented and will lead to a withdrawal of services available to the public.

Permitting tort claims against corporate trustees, particularly in relation to

the malfeasance of a trust grantor and a trust beneficiary as is the case presented

here with NPS, is unprecedented. The risk exposure of a trustee will no longer be

related to the value of the trust account assets under management (See definition

Trust Department) or bear any relation to the duties to the beneficiary under the

trust instrument (agreement or declaration) or other governing law to take

appropriate measures to protect trust assets. Further, under this case the Special

Deputy Receiver seeks to hold the trustee, in effect, vicariously liable for the

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tortious conduct of the trust grantor and beneficiary. A trustee, of course has no

power or duty to direct the activities of a trust creator or a beneficiary.

Tort claims combined with vicarious liability for the actions of a trust

grantor and beneficiary introduce a new legal risk to a trust company’s operations.

Unless the district court’s ruling is reversed, a trust company would necessarily

have to both assess and continually monitor the character of the management of

the trust grantor and trust beneficiaries, the trust grantor’s and beneficiary’s

current and future business conduct, and the vicissitudes that affect the business

affairs of such person. The services and the pricing of services by banks and trust

companies must always reflect risk.

If risk cannot be reasonably quantified then services will be withdrawn or

not be offered at all. Trust companies, rather than acting in the sole capacity of a

fiduciary to hold legal title to property to manage and safeguard trust property

pursuant to the directions of the trust grantor and to the use and benefit of the trust

beneficiary, will necessarily be pressed into service as arbiters of what constitutes

a right, good, or proper business enterprise or industry and what makes right, good

or proper business policies and practices for a trust grantor and beneficiary.

Because trustees have neither the capacity nor the legal authority to perform

such a function, this scenario will lead banks and trust companies to withdraw

trust services from certain industries and businesses. But, even more disturbing is

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that the business of a trust company has never previously been that of insuring

contingent and uncertain liabilities or indemnifying trust beneficiaries or trust

grantors against third party claims. Trust companies will necessarily price their

services higher and build costly capital reserves with the result that the public will

pay more for fiduciary services that are at the same time offered on a more limited

or restricted basis.

II. BANKS AND CORPORATE TRUSTEES RELIED UPON STATUTES GOVERNING PRE-NEED CONTRACTS IN DECIDING WHETHER TO ACCEPT AND HOW TO PRICE TRUST BUSINESS. It is important to place Missouri’s Funeral Contract Law and Missouri’s

Preneed Funeral Contract Act into the context of the facts in the underlying case.

In late 2007, insurance regulators discovered the fraudulent activities of NPS and

forced its related insurance companies into receivership. PNC brief, p. 10. As this

massive fraudulent scheme unfolded, the Missouri General Assembly responded

by enacting S.B. 1, Laws 2009, which repealed the entirety of Missouri’s “Funeral

Contract Law” sections 436.005 to 436.071 and replaced it with the “Missouri

Preneed Funeral Contract Act” sections 436.400 to 436.520. See, S.B. No. 1,

Laws 2009 and Section 436.440 (the bill presents the repealed sections). The prior

act originated in 1982. The repealed sections and the trust agreements drawn by

NPS, as the trust grantor, under the repealed statue control this case.

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Under Section 436.005, the individual whose body will be disposed of is

defined as a “beneficiary” of the services, facilities and merchandise described in

a pre-need contract. This individual and their estate are the beneficiaries of the

contract, but, under the Funeral Contract Law, this person is not however, the

beneficiary of the trust established pursuant to Sections 436.005 to 436.071. The

only person authorized to receive a distribution from the pre-need trust is the

seller.

Under Section 436.045, the seller can obtain the deposits to the trust related

to a particular contract after the provider has performed the services required

under the contract and after the seller has paid the provider pursuant to the written

contract between the seller and provider. Thus, under Missouri’s statutory scheme

the seller is both the grantor and the beneficiary of the trust. The seller/grantor is

the sole beneficiary for payments of principal and income from the trust under

Sections 436.045 and 436.031.

A. The statute permitted the pre-need seller to appoint an independent, qualified registered investment advisor to make all decisions about the investment and liquidation of the trust assets.

Section 436.031(2) permitted the pre-need seller to appoint an independent,

qualified, and registered investment advisor to make all decisions about the

investment and liquidation of trust assets. The statute conditioned the pre-need

seller’s power of appointment upon the amount of the accumulated principal and

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interest in a pre-need trust, providing that when this amount exceeds $250,000, the

pre-need seller (trust grantor) may hire a federally registered or Missouri-

registered independent qualified investment advisor. The statute provided in the

event the trust grantor hired an independent qualified investment advisor, the

“trustee shall be relieved of all liability regarding investment decisions made by

such qualified investment advisor.” Id. (emphasis added.)

B. The corporate trustee’s services differed when the pre-need seller used an investment advisor. Banks and corporate trustees relied upon the statutes governing pre-need

contracts in making decisions on whether to accept and how to price trust

business. Banks and trust companies offer administrative as well as investment

services. A “custody account” is “(2) an account held by a custodian for an

institution such as a mutual fund, pension fund or corporate customer. The bank

holds the customer’s property in safekeeping, as provided by a written agreement,

collects dividends and interest payments, and sells or delivers securities when

directed by the principal.” Dictionary of Banking Terms, supra. With respect to

custodial account services, in the context of this case, the trustee was effectively a

custody agent for the assets placed in trust. Banks and trust companies charge

lower prices to trust grantors when the only services to be provided are custodial,

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administrative services. See e.g., Davis v. U.S. Bank Nat’l Assoc., 243 S.W.3d

425, 429 (Mo.App. 2008)

Under Chapter 436, when the pre-need seller appointed an investment

advisor, the funeral contract trusts were purely administrative and custodial as the

only trust services provided were to maintain custody of the trust assets for the

benefit of the trust grantor and beneficiary, which under the law, were the same.

The investing and distribution of the trust assets were directed by the registered

investment advisor under the law and under the declarations of the trust

instruments.

C. By statute the corporate trustee was relieved of duties of managing the investments and liability for investment decisions when the pre-need seller hired and used an investment advisor. Further, when a pre-need seller appoints an investment advisor, as was done

in the instant case, the trustee—by statute—is also expressly relieved of the duties

of managing the investments and liability for investment decisions made by the

investment advisor1. The choice to use and the choice of the investment advisor is

that of the trust grantor (in this case the pre-need seller). If the trust grantor

chooses to hire and use an investment advisor for the discretionary investment

1 Though §436.031 was repealed in 2009, pursuant to §436.440.6, trusts in existence as of August 28, 2009 are still permitted to utilize the services of an independent financial advisor if the advisor was in place pursuant to §436.031 as of August 28, 2009.

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decisions relating to the trust, the trustee does not charge for or undertake

management of any trust investments. Instead, the trustee charges a lower price for

providing administrative services regarding the custody of the trust property.

Another adverse result to trust law is that a commercial trust company will

not accept trust management where the trust creator has allocated authority to one

or more persons other than the trustee to direct or control certain activity including

trust investments or distributions. The district court’s opinion disregards the law

of trusts, both the common law and the Missouri Uniform Trust Code. The district

court’s opinion treats the pre-2009 Missouri law of funeral contracts with 20-20

hindsight with regard to section 436.031 where even the Missouri General

Assembly did not foresee that a pre-need contract seller would corrupt both a

registered and regulated investment advisor vested with fiduciary duties under the

law and under a trust instrument as well as defraud and bankrupt two regulated

insurance companies. In this case massively fraudulent conduct went undetected

for years by the regulators for funeral directors, pre-need sellers, insurance

regulators, bank and trust regulators (all with audit and examination powers

unavailable to the trustee) and state attorneys general with enforcement and

subpoena powers.

No trust company or trust officer would have charged the trust beneficiary

for services it did not anticipate or have a responsibility to perform—namely,

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investment decisions when the trust grantor chose an investment advisor to

perform those duties and responsibilities. Nor could they have. A trustee may only

incur reasonable costs in administering a trust. See Section 456.8-805. No

Missouri trust company or trust officer would conclude or conceive, from a review

of statutory and common law, that the trustee would be responsible for or have a

duty to police the investment activities of an investment advisor.

III. DAMAGES FOR BREACH OF A TRUSTEE’S DUTIES ARE TIED TO THE VALUE OF THE PROPERTY THE TRUSTEE IS ENTRUSTED TO PROTECT. The district court compounded its error when it declined to apply the trust-

law measure of damages. Banks and trust companies accept trust business based

on the long-understood concept that damages for a breach of fiduciary duties,

including, a negligent breach of fiduciary duties, is measured by the loss in value

of the property entrusted to the trustee and the trustee’s profit from the breach, or

the loss of profit to the trust. “If the trustee breaches his trust, the beneficiary is

entitled to recover (a) loss in value of the trust property attributable to the breach,

(b) profit inuring to the trustee from the breach, or (c) loss of profit to the trust

which would have otherwise have accrued but for the breach.” Barnett v. Rogers,

400 S.W.3d 38, 49, 50 (Mo.App. 2013), quoting, Parker v. Pine, 617 S.W.2d 536,

540 (Mo.App. 1981). Missouri’s General Assembly codified this measure of

damages in the Missouri Uniform Trust Code, see §456.10-1002.

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A. Courts do not permit tort law measures of damages in breach of trustee duty cases.

The district court’s actions are unprecedented in permitting the expansion of

trustee liability from equity, where the scope of duties and damages for any breach

is quantifiable and defined, to tort liability where no such limits exist. No prior

case has found such an expansion to be appropriate. Absent reversal, the chilling

effect on corporate trustees will result in either much higher trust fees or a loss to

the public of available services, or both.

Missouri trust law has always limited a trustee’s responsibility for damages

to the management of the trust assets in the Missouri trust. The district court’s

opinion is devastating in permitting the jury to award the staggering amount of

$355.5 million without proof of the amount of harm to the trust estate and

awarding damages based on effective vicarious liability for conduct by the trust

grantor and beneficiary, and for conduct occurring outside Missouri and for loss of

assets that were never in the Missouri trust.

B. Courts do not hold corporate trustees responsible for the extraterritorial acts of a trust grantor and beneficiary or for acts that did not involve property held in the Missouri trusts.

Missouri trustees should not be held responsible for the extraterritorial acts

of the trust grantor and beneficiary or for acts that did not involve property

delivered to the Missouri trusts and that did not affect the Missouri trust assets.

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Trust companies would have to re-consider their retention or acceptance of many

types of client and trust relationships if they are exposed to non-equity claims for

breaching their duties as trustee, vicarious liability for the actions of the trust

grantor and beneficiary, and damages that go beyond the scope of the relationship

and beyond the assets placed in the trusts.

In the instant case, plaintiffs claimed $355.5 million in compensatory

damages from PNC. Pursuant to trust law, the permissible damages should not

have exceeded the proven loss to the Missouri trust assets. However, plaintiffs

never presented evidence of the amount of losses, if any, suffered by the Missouri

trusts. Instead, the district court nullified the law of trusts and permitted PNC to

be held liable for the entire fraud committed by NPS, the insolvency of two

insurance companies never owned or managed in the trust, and fraudulent

activities NPS conducted in 18 other states. No trust company or trust officer

would anticipate liability for frauds committed by the trust grantor and beneficiary

for actions conducted outside Missouri or for loss to property never held in the

Missouri trusts or for the insolvency of two out-of-state insurance companies that

were never trust property. Under traditional trust law, plaintiffs would not have

prevailed, because they never presented evidence of any loss to the property

contained in the Missouri trusts. Reversal is warranted because the damages

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permitted in the underlying case had nothing to do with the property delivered and

entrusted to the trustee.

C. If the scope of damages is expanded, the pricing and availability of trust services in Missouri will be adversely affected.

The district court’s opinion will impact the pricing and availability of trust

services in Missouri. Trust companies base pricing on known responsibilities and

a known measure of damages for a breach of fiduciary duties tied to the value of

the trust estate. If the district court’s ruling is permitted to stand, trust companies

will not know how to price trust management and services. A Missouri trustee

would never anticipate liability for more than the value of the property entrusted to

the trustee or vicarious liability for the tortious conduct of the trust grantor or

beneficiary.

The effect of the opinion is to override what the Missouri legislature

permitted and re-allocate costs and risks after the fact. Corporate trust services

will be less available and more expensive to the public. Businesses that require

corporate trust services will pass these costs on to their customers.

A Missouri bank trustee paid to provide administrative services, with no

power to direct the investment of assets in trust, should not be held responsible to

monitor the lawfully appointed registered investment advisor, or be subjected to

vicarious liability for the trust grantor’s and beneficiary’s actions occurring

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outside Missouri. A trustee has no power or authority to direct the general

business affairs of a trust grantor or trust beneficiaries. In this case, NPS and the

insurance companies were not property delivered into the trust to be managed and

directed by the trustee. If the trustee’s negligence in performing fiduciary duties

causes a loss in value or improper distribution of the trust asset, the trustee is

responsible for damage caused to by the loss in value or the loss of the asset itself.

However, the damages permitted by the district court had nothing to do with the

duties owed to the beneficiary and charged to the trustee. The inherent defect of

the district court’s opinion is the whole calculus of damages bears no relationship

to the breach of the fiduciary’s duties or the loss in value for the trust assets placed

with the trustee. As urged in PNC’s brief, reversal by this Court is not only

warranted, it is imperative.

CONCLUSION

For the reasons set forth above, this Court should reverse the District

Court’s Judgment and enter Judgment in favor of Appellees or in the alternative,

reverse and remand for a new trial.

/s/ Susan Ford Robertson SUSAN FORD ROBERTSON #35932 The Robertson Law Group, LLC 1903 Wyandotte, Suite 200 Kansas City, MO 64108 816-221-7010 (phone) 816-221-7015 (fax)

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Counsel for Amici Curiae American Bankers Association and Missouri Bankers Association

CERTIFICATE OF COMPLIANCE

I, Susan Ford Robertson, counsel for Amici Curiae Missouri Bankers

Association and American Bankers Association, and a member of the Bar of this

Court, certify, pursuant to Federal Rule of Appellate Procedure 32(a)(7)(B), that

the attached brief of Amici Curiae is proportionately spaced, has a typeface of 14

points or more, and contains 3,913 words.

/s/ Susan Ford Robertson SUSAN FORD ROBERTSON March 15, 2016

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CERTIFICATE OF SERVICE

I, Susan Ford Robertson, counsel for Amici Curiae Missouri Bankers

Association and American Bankers Association, certify that on March 15,

2016, a copy of the attached Brief of Amici Curiae was submitted for filing

through the appellate CM/EDF system with the Clerk of the Court.

/s/ Susan Ford Robertson March 15, 2016


Nos. 15-3872(L), 15-3878 In the United States Court of ... · Jo Ann Howard & Associates, et al.,...

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