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Court of Chancery Declines To Restrain Controller In Proposed Viacom-CBS Deal

CBS Corp., et al. v. National Amusements, Inc., et al., C.A. No. 2018-0342-AGB (Del. Ch. May 17, 2018) (Letter Op.) - Arising out of the highly-publicized dispute over the proposed transaction involving CBS and Viacom,...more

Court Of Chancery Upholds Waste Claims

R.A. Feuer v. Redstone, C.A. 12575-CB (April 19, 2018) - This decision involves the rare case where a waste claim is well plead. ...more

Delaware Superior Court Clarifies Jurisdiction Over Negligent Representation Claims

Wypie Investments LLC v. Homschek, C.A. N14C-08-140 WCC CCLD (March 28, 2018) - This decision clarifies that negligent representation claims can only be brought in the Delaware Court of Chancery. ...more

Court Of Chancery Explains When A Minority Stockholder Has Control

In re Tesla Motors Inc. Stockholder Litigation, C.A. No. 12711-VCS (Del. Ch. Mar. 28, 2018) - Under Delaware law, a controlling stockholder need not be a majority stockholder. Rather, a controlling stockholder might be a...more

Court Of Chancery Explains When Directors Lack Independence To Consider Pre-Suit Demand

In Re Oracle Corporation Derivative Litigation, C.A. No. 2017-037-SG (Del. Ch. Mar. 19, 2018) - Delaware law requires a derivative plaintiff to make a pre-suit demand on the board unless excused as futile. Because some...more

Court of Chancery Applies Revlon to a Warrant to Buy

Carr v. New Enterprise Associates, Inc., C.A. No. 2017-0381-AGB (Del. Ch. Mar. 26, 2018) - This decision addresses a host of interesting topics. First, it declines to invoke the so-called step-transaction doctrine under...more

Court Of Chancery Awards Nominal Damages For Breach Of Fiduciary Duty

The Ravenswood Investment Company LP v. The Estate Of Bassett S. Winmill, C.A. No. 3730-VCS (Del. Ch. Mar. 21, 2018) - It is easy to assume that some form of meaningful relief must be available when a fiduciary bears the...more

Is Stockholder Litigation in Trouble in Delaware? An Update

A series of recent Delaware court decisions have caused some plaintiffs law firms to decide stockholder litigation should no longer be filed in the Delaware courts. This article will first explain the background to their...more

Court Of Chancery Explains Proper Evidence To Support Inspection Claim

In Re UnitedHealth Group Inc. Section 220 Litigation, C.A. 2017-0681-VCMR (February 28, 2018) - To obtain inspection rights from a Delaware corporation to investigate alleged wrongdoing, the petitioner needs some evidence...more

Court Of Chancery Holds Demand Is Not Excused When Only Best Practices Were Not Followed

Wilkin v. Narachi, C.A. 12412-VCMR (February 28, 2018) - Demand on directors is not required when it is alleged that they have violated a statute or rule. But when the claim is only that they violated the "best practices”...more

Court of Chancery Explains DGCL Section 141

Cummings v. Eden, C.A. 13007-VCS (February 20, 2018) - This decision is particularly helpful in clarifying the effect of Section 141 of the DGCL. A transaction that is passed by the vote of even a single disinterested...more

Supreme Court Clarifies Need To Disclose A Director’s Opinions

Appel v. Berkman, No. 316, 2017 (February 20, 2018) - When seeking stockholder votes it is not always clear when the company must disclose an opinion of an individual director on the merits of the proposed transaction....more

Court Of Chancery Interprets Dell In An Appraisal Case

In RE Appraisal Of AOL Inc., C.A. 11204-VCG (February 23, 2018) - This is an important case for its comments on the Dell decision of the Delaware Supreme Court. The Court declined to use the deal price as evidence of the...more

Court Of Chancery Resolves Allocation Issues In Advancement Case

Weil v. Vereit Operating Partnership LP, C.A. 2017-0613-JTL (February 13, 2018) - This decision clearly sets out how to allocate fees for claims subject to advancement of attorney fees from those that are not covered by an...more

Court Of Chancery Explains When A Prediction Is A Misleading Disclosure

Chatham Asset Management LLC v. Papanier, C.A. No. 2017-0088-AGB (Dec. 22, 2017) - It is often said that a mere prediction of some future event cannot be misleading because such predictions are speculations that cannot be...more

Court Of Chancery Explains Caremark Claims

Oklahoma Firefighters Pension & Retirement System v. Corbett, C.A. 12151-VCG (December 18, 2017) - This decision is an exhaustive review of what constitutes a Caremark claim. It makes it clear that merely because the...more

Delaware Supreme Court Explains When Derivative Case May Be Dismissed

City of Birmingham Retirement and Relief System v. Good, No. 16, 2017 (December 15, 2017) - This decision explains again that actual or constructive knowledge of persistent corporate wrongdoing is needed before there is a...more

Delaware Supreme Court Clarifies Ratification Defense In Stock Option Cases

In re Investors Bancorp Inc. Stockholder Litigation, No. 169, 2017 (December 13, 2017) - There has been some uncertainly over the effect of stockholder approval of stock option plans for directors, such as does that...more

Court Of Chancery Expands MFW To Recapitalization

IRA Trust FBO Bobbie Ahmed v. Crane, C.A.. 12742-CB (December 11, 2017) - This is an important decision because it extends the holding of MFW to a stock reclassification. Under the 6-part test of MFW, the business judgment...more

Court Of Chancery Enforces Oral Agreement To Add Directors

Sarissa Capital Domestic Fund LP v. Innoviva Inc., C.A. 2017-0309-JRS (December 8, 2017) - This is a great explanation of when a director is authorized to enter into an oral agreement that is enforceable, here to add two...more

Court Of Chancery Explains Basis For Inspection Of Alleged Wrongdoing

Silverberg v. ATC Healthcare Inc., C.A. 2017-0242-JRS (December 5, 2017) - While the standard to win the right to inspect corporate records to investigate alleged wrongdoing is a lenient one, it is still not enough to just...more

Be Careful What You Ask For in a Section 225 Case

Delaware recognizes the need to promptly resolve disputes over the composition of the board of directors of a Delaware corporation. Section 225 of the Delaware General Corporation Law provides that the Delaware Court of...more

Court Of Chancery Issues A Definitive Opinion on Aronson

Lenois v. Lawal, C.A. No. 11963-VCMR (Nov. 7, 2017) - This case illustrates the power of well-functioning special committee to diffuse the potentially corruptive influence of a self-interested controller on a transaction....more

Court Of Chancery Explains When Side Deals Are Actionable Under A Bad Faith Theory

Kahn v. Stern, C.A. No. 12498-VCG (Aug. 28, 2017) - It is not easy to sufficiently plead a bad faith breach of fiduciary duty by a board in approving a merger when a majority of the directors were disinterested and...more

Court Of Chancery Gives Guidance On What Constitutes Bad Faith

In Re Meadwestvaco Stockholders Litigation, C.A. No. 10617-CB (August 17, 2017) - As this decision explains, to state a claim attacking a merger on the basis that the Board acted in bad faith you need more than ...more

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