Boyd v. Farrin
958 F. Supp. 2d 232
D.D.C.2013Background
- Plaintiffs NBFA and its president Boyd sue Farrin and Marks after Pigford II settlement fees; they claim breach of fiduciary duty, quantum meruit, and breach of contract.
- Pigford I/II litigation arose from decades of discrimination against black farmers and resulted in settlements and funds for late filers; NBFA and Boyd advocated for more funds.
- Pigford II settlement allocated attorneys’ fees to class counsel; plaintiffs allege defendants promised payment for Boyd’s advocacy but did not pursue compensation.
- Court previously ruled Boyd could not participate as a Pigford II plaintiff and NBFA could not join as a Pigford II settlement class member; nonlawyers cannot recover attorney fees.
- Plaintiffs seek compensation in this suit, but standing and pleading deficiencies prompt the court to grant the defendants’ motions to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do plaintiffs have standing to seek compensation from Pigford II funds? | Boyd/NBFA claim injury from failure to obtain compensation. | No legally protected interest; they cannot recover as nonparties or nonclass members. | Lack of standing; NBFA dismissed; Boyd cannot claim settlement-based damages. |
| Does Boyd state a viable breach of fiduciary duty claim against the defendants? | Defendants owed fiduciary duties to Boyd due to representation. | Defendants represented NBFA and Pigford II plaintiffs, not Boyd personally. | No fiduciary-duty relationship with Boyd established; claim dismissed. |
| Does Boyd state a viable breach of contract claim? | Verbal promises to pay Boyd for time and expenses constituted a contract. | No definite agreement or material terms alleged; insufficient detail. | Insufficient contract formation and terms; claim dismissed. |
| Does Boyd state a viable quantum meruit claim? | Plaintiff reasonably expected to be paid for services. | No specifics showing reasonable notice or defendant awareness of payment expectation. | Inadequate factual detail; quantum meruit claim dismissed. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury-in-fact, concrete and particularized)
- Twombly, 550 U.S. 544 (2007) (pleading must show plausibility, not mere conclusory statements)
- Iqbal, 556 U.S. 662 (2009) (pleading must contain plausible facts supporting claims)
- DC v. Air Fla., Inc., 750 F.2d 1078 (D.C. Cir. 1984) (pleading standards and pleading requirements)
- Oglala Sioux Tribe v. United States Army Corps of Engineers, 537 F. Supp. 2d 161 (D.D.C. 2008) (standing and protected interests concepts)