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The “Business Judgment Rule” Applies in LLCs Too

Corporate directors have long relied on the “business judgment rule,” under which their decisions are presumed to have been made “on an informed basis, in good faith, and in the honest belief that the action taken was in the...more

Court Rules Grower Cannot Use Access Easement for Cannabis Purposes Without Servient Landowner’s Consent

While many Californians consider the legality of cannabis to be settled law, the ongoing conflict between California and federal laws on the subject continue to give rise to unexpected outcomes when it comes to real property...more

Non-Compete Agreements in Connection with Partial Sale of LLC Interest

With certain narrow exceptions (including in connection with the sale of the “goodwill” of a business), agreements restraining competition face an uphill battle in California.  As a matter of public policy, California law...more

Transferring Property in Violation of a Court Order is Not a Good Idea

The “right to alienate” (transfer) property is an important part of the legal “bundle of rights” regarding property ownership. But those rights, like most others, can be altered by court orders....more

Claim for Breach of Fiduciary Duty Might be Subject to the “Internal Affairs Doctrine”

In a prior LLC Jungle post — Think Carefully Before Forming an “Out of State” LLC — we reviewed a published opinion (Boschetti v. Pacific Bay Investments Inc.) holding that a claim for Judicial Dissolution of an LLC was...more

LLC Members May Ratify Prior Defective Actions

Actions taken within business entities are sometimes deemed invalid due to procedural defects.  For corporations, section 119 of the Corporations Code establishes a clear procedure by which defective actions can be ratified...more

Receivers Gone Wild

Receivership is a provisional remedy within a court’s broad equitable jurisdiction.  The statute most commonly used in obtaining a receivership is Code of Civil Procedure section 564.  But other statutes sometimes apply, such...more

7/29/2024  /  Foreclosure , Jurisdiction , Rent

To Moot a Statutory Buyout, LLC’s Dissolution Must be Valid Under its Operating Agreement

In 2022, The LLC Jungle covered the opinion Friend of Camden, Inc. v. Brandt in a post titled LLC Dissolution Vote Defeats Statutory Buyout. In the Friend of Camden case, the Court of Appeal held that an LLC membership vote...more

The Perils of Buying Property from an LLC with Competing Claims to Managerial Authority

Prior LLC Jungle posts have addressed the tricky issue of LLC managerial authority in the context of the LLC’s dealings with third parties... As referenced in those posts, under Corporations Code section 17703.01, when an...more

LLC Member Acting for LLC Without Authority Is Not “Protected Activity” Under California’s Anti-SLAPP Statute

California’s anti-SLAPP statute (Code of Civil Procedure section 425.16) aims to protect defendants from meritless lawsuits designed to chill “protected activity” — i.e., the exercise of rights of petition (litigation) or...more

Eviction After Foreclosure: Further Developments from the Courts

A foreclosure sale purchaser attempting to evict a tenant on the property can encounter pitfalls, as made clear in a series of court cases in recent years.  Here is a summary, capped by an update on a recently filed...more

LLC Manager’s Conduct Benefits Her Side Entity at the Expense of the LLC — Are the Claims Against Her Direct or Derivative?

The distinction between direct and derivative claims is a recurring theme on The LLC Jungle. In a nutshell, under California law, an LLC (just like a corporation) is treated as a legal entity separate and distinct from...more

Court Permission Required for a Second Lis Pendens

A recorded lis pendens notifies prospective purchasers, encumbrancers, and transferees that there is litigation pending that affects the property.  To curb abuses of the lis pendens process, the Legislature enacted amendments...more

Operating Agreement Doesn’t Excuse Breach of Fiduciary Duty

Many posts on The LLC Jungle blog have focused on the fiduciary duties owed by LLC managers to both the LLC’s members and the LLC itself. Other posts have focused on the pitfalls of LLC Operating Agreements that fail to...more

California Supreme Court: Parties to a Real Estate Transaction Can Create Implied Exclusive Easements

In the recent case Romero v. Shih, the California Supreme Court clarified that under California law, parties to a real estate transaction may create an implied easement that effectively grants the dominant tenement exclusive...more

Derivative Claim Upheld for Estate of Deceased LLC Member

Asserting claims derivatively on behalf of an LLC, as opposed to directly on behalf of an LLC member, can be tricky business for even experienced litigators.  The requirements for derivative claims have been explored in...more

Partnership — Not Its Partners — Owns Malpractice Claim Against Partnership’s Attorney

Two important principles governing corporate entities are: (1) the entity is legally distinct from its owners; and (2) the entity’s property and assets belong to the entity, not its owners. These themes are...more

Guarantor Liability: Assignment of Note Doesn’t Automatically Assign Guaranty Too

Obligations reduced to a promissory note are often accompanied by a written guaranty. The law treats the guaranty as an independent obligation. A case recently decided by California’s First District Court of Appeal —...more

Does an LLC’s Bankruptcy Discharge Apply to the LLC’s Alter Egos?

When a debtor LLC receives a discharge order from a bankruptcy court, a creditor is prevented from enforcing any preexisting debts against the discharged LLC as a personal liability.  This is known as the “discharge...more

Another Case Addressing Managerial Discretion and the Implied Covenant of Good Faith and Fair Dealing

LLC managers often enjoy wide latitude and unrestricted “discretion” under the LLC’s operating agreement. At the same time, all contracts — including LLC operating agreements — are subject to the implied covenant of good...more

A Lis Pendens Recorded Before a Trustee’s Sale is a “Cloud on Title” that Might Thwart an Unlawful Detainer Claim

In a December 2018 post, Money and Dirt covered a California Supreme Court case — Dr. Leevil, LLC v. Westlake Health Care Center — in which the Court held: “an owner that acquires title to property under a power of sale...more

Receiver for LLC Can be Bound by Operating Agreement’s Arbitration Provisions

Courts often appoint receivers to manage the affairs of LLCs when the internal management is conflicted or broken. General equity receivers (as opposed to more limited receiverships such as deed of trust receivers) enjoy...more

Relying on a Void Quiet Title Judgment — Redux

In May 2021, Money and Dirt covered a case published by California’s Second Appellate District — Tsasu LLC v. U.S. Bank Trust, N.A. — holding that under Code of Civil Procedure section 764.060 (part of California’s Quiet...more

Alter Ego — No Single Factor is Determinative

Alter ego liability is again the flavor of the day... As previously covered, the alter ego doctrine allows a court to disregard a corporate entity (including LLCs) and hold the individual owners liable for claims against...more

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