Robertson v. Jacobs Cattle Co.

Jacobs Cattle Company (JCC) (defendant), a family partnership, owned farmland and rented it to others. JCC’s partners consisted of Ardith Jacobs (defendant); Ardith’s children, including Dennis Jacobs (defendant) and Patricia Robertson (plaintiff); and Patricia’s husband, James Robertson (plaintiff). The partnership agreement gave Ardith broad management authority to run the day-to-day business of JCC. Patricia and James rented land from JCC. JCC, at the direction of Ardith, successfully sued Patricia and James for unpaid rent. The partners agreed that JCC could not continue to function with Patricia and James as partners. Patricia and James commenced an action to dissolve the partnership. JCC, Ardith, and Dennis asked the court to order the dissociation of Patricia and James from the partnership, rather than dissolve the partnership, and proposed a buyout of Patricia’s and James’s partnership shares measured from May 2005, when the nonpayment of rent occurred. The court declined to dissolve the partnership and, in September 2011, ordered the dissociation of Patricia and James from the partnership. Patricia and James appealed. The court also directed that the value of Patricia and James’s interest in JCC, for the purpose of determining the amount for which the remaining partners would be required to buy out Patricia and James, was to be measured as of September 2011, the date of the dissociation order, rather than May 2005, the date that Patricia and James failed to pay rent. JCC, Ardith, and Dennis cross-appealed.