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In Delaware, You Live or Die Under Your LLC Operating Agreement

Put on your Member B hat in the following not-so-hypothetical fact pattern: Member A and Member B form a Delaware LLC to invest in a third-party biotech company....more

One Very Messy LLC Freeze-Out Merger

Loyal readers of this blog may recall the powerful victory my firm’s client won in 2021 in Farro v Schochet, where the Appellate Division, Second Department broke new ground by holding inapplicable to LLC freeze-out mergers...more

Top 10 Business Divorce Cases of 2025

Welcome to our 18th annual edition of the Top 10 business divorce cases featured on this blog over the past year. This year’s selections include a split decision by the New York Court of Appeals in a fascinating case...more

Score Another Round for the Estate: First Department Upholds Right of Deceased LLC Member’s Executor to Pursue Member Rights

In recent years this blog has closely followed caselaw developments concerning the powers of estate representatives of deceased LLC members to exercise member rights under Section 608 of the LLC Law....more

Does This California Case Bolster the Argument Against Waiver of the Right to Seek Judicial Dissolution of New York LLCs?

California lawyer and publisher of The LLC Jungle blog, Kevin Brodehl, recently posted about an interesting decision earlier this month by a California intermediate appellate court in a case called Meads v Driggers....more

A Wolf in Sheep’s Clothing: Shareholder Agreement’s “Except as Otherwise Set Forth Herein” Hands Control of Famed Restaurant to...

John’s of 12th Street in the East Village is one of Manhattan’s oldest and most storied red-sauce Italian restaurants. Founded in 1908, John’s hosted a speakeasy and was favored by gangsters during Prohibition. In 1922, it...more

Summer Shorts: A Trio of Recent Decisions of Interest in LLC Member Disputes

Welcome to this 15th annual edition of Summer Shorts. This year’s edition features brief commentary on a trio of recent decisions by New York courts in business divorce cases, all involving LLCs, including: A relatively...more

On Camera: My Recent Video Interview on, What Else, Business Divorce (Part 2)

This post features Part 2 of a recent two-part program to be later aired on New York City public access cable in which I was interviewed by Sandra Schulte on an array of topics in the business divorce universe. Sandra has...more

On Camera: My Recent Video Interview on, What Else, Business Divorce (Part One)

I recently had the pleasure of being interviewed by Sandra Schulte at the media production studios of the Manhattan Neighborhood Network located near the Javits Center. Sandra, whom I met at a CLE program where I was a...more

The Consequences of Deception: Defendant Hit With $4.5 Million Judgment After 12-Year “Wild Goose Chase Based on a Lie”

“Down the ridiculous rabbit hole,” “magical math,” “smoke and mirrors,” “sixteen-year charade.” That’s how the plaintiff’s post-trial brief in Becker v Perla described the defendant’s reverse-field disavowal of his sworn...more

Retirement of Working Owners of Closely Held Business Entities: What’s Your Plan?

It’s a fact that the great majority of multi-owner, closely held business entities are run by working owners. In many if not most instances the working owners realize the financial benefits of ownership primarily in the form...more

LLC Minority Member Gets Caught in His Own “Wolverine Trap”

Over the years I’ve become less enamored with arbitration as an alternative to litigating complex business cases in court, mostly because the traditional trade-off between abundant due process protections (court) versus...more

Court’s Decision in High Stakes Case Cuts Through the “Fog of Dueling ‘Notwithstanding’ Clauses”

In a post I wrote about a dozen years ago, I quoted Ken Adams, blogger and author of A Manual of Style for Contract Drafting, who, commenting on the oft-used contract clause, “Notwithstanding anything to the contrary in this...more

I’ll Have a Bacon Cheeseburger, Hold the Pickle and LLC Dissolution

I’ve noticed over the many years since this blog’s launch a disproportionate number of posts concerning disputes among restaurant co-owners. The only explanation I’ve come up with is that first-time, start-up restaurant...more

New York Top Court’s Advice to Prospective Investors in Delaware LLCs: Pay Close Attention to Controller’s Power to Amend LLC...

Opinions by the Court of Appeals, New York’s highest court, construing the state’s LLC Law enacted 30 years ago are almost but not quite as rare as hen’s teeth. The great majority of important rulings under the statute...more

The Little Buy-Sell That Could

With apologies to the pseudonymous children’s book author Watty Piper, this is the story of a humble buy-sell provision in a family-owned LLC’s operating agreement that temporarily ran out of steam in the lower court, only to...more

Top 10 Business Divorce Cases of 2024

Welcome to our 17th annual edition of the Top 10 business divorce cases featured on this blog over the past year. This year’s selections buck the trend of previous years in which cases involving limited liability...more

Diving Into the Shallow Waters of New York Law Permitting Elimination of LLC Managers' Liability for Breach of Fiduciary Duty

There’s a ton of Delaware caselaw enforcing Section 18-1101 (c) of that state’s LLC Act as amended in 2004, authorizing LLC agreements to eliminate the members’ and managers’ liability for breach of fiduciary duty, the only...more

Diving Into the Shallow Waters of New York Law Permitting Elimination of LLC Managers’ Liability for Breach of Fiduciary Duty

There’s a ton of Delaware caselaw enforcing Section 18-1101 (c) of that state’s LLC Act as amended in 2004, authorizing LLC agreements to eliminate the members’ and managers’ liability for breach of fiduciary duty, the only...more

Appellate Division Construes LLC Law 608 as Giving Voting Rights to a Deceased Member's Estate

It wasn’t long ago that my partner, Peter Sluka, posted about the Andris case where the Appellate Division, Second Department, reinstated an LLC judicial dissolution proceeding brought by the estate of a deceased member....more

Foreign Affairs of the Books and Records Kind

Some years ago, the question whether New York courts have subject matter jurisdiction over petitions to dissolve foreign business entities garnered much interest amongst business divorce lawyers and on this blog. The debate...more

Appellate Division Construes LLC Law 608 as Giving Voting Rights to a Deceased Member’s Estate

It wasn’t long ago that my partner, Peter Sluka, posted about the Andris case where the Appellate Division, Second Department, reinstated an LLC judicial dissolution proceeding brought by the estate of a deceased member. ...more

Recent Appellate Rulings Address Novel Issues in General Partnership Disputes

The era of the old-fashioned general partnership long ago petered out, largely displaced by subchapter S corporations and, in the last few decades, limited liability companies, both of which allow pass-through taxation...more

Summer Shorts: An Unusual Application of LLC Law § 608 and Other Decisions of Interest

Welcome to this 14th annual edition of Summer Shorts. This year’s edition features brief commentary on three recent decisions by New York courts in business divorce cases. The featured cases involve a suit pitting three...more

Did Chancery Court Just Crack Open the Door to Equitable Dissolution of LLCs?

Delaware Chancery Court’s contractarian approach to all things LLC, embedded statutorily in Section 18-1101(b) of the Delaware LLC Act (“It is the policy of this chapter to give the maximum effect to the principle of freedom...more

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