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Post-Election Regulatory Changes to Corporate Governance Mirror Broader Political Shift

Significant post-election shifts in corporate governance policy are already occurring among regulators, self-regulatory organizations and proxy advisors. The SEC will no longer litigate its climate disclosure rules,...more

No Toll for Corporations Leaving Delaware on a Clear Day

Delaware Supreme Court holds business judgment rule applies to decision to reincorporate a company out of Delaware made on a “clear day.” For a non-ratable benefit to give rise to a conflict and trigger entire fairness,...more

Delaware Supreme Court Reaffirms High Bar for Proving Control by a Minority Stockholder

Delaware Supreme Court reaffirms that “the test for actual control by a minority stockholder is not an easy one to satisfy.” Supreme Court makes clear that control by a minority stockholder is “not presumed.” Supreme Court’s...more

Delaware Governor Signs Controversial “Market-Practice” Amendments to General Corporation Law

Amendments were adopted to restore market practices impacted by three recent Court of Chancery decisions. Amendments simplify the approval of a merger by a board of directors, thereby removing the potential for certain...more

Delaware Court of Chancery’s Rescission of Elon Musk’s US$55.8 Billion Pay Package Signals Expansion of Scrutiny into Potential...

The Delaware Court of Chancery issued a post-trial opinion, on January 30, 2024, in Tornetta v. Musk, holding that Tesla’s board of directors (the “Board”) breached its fiduciary duties in awarding CEO Elon Musk (with the...more

Delaware Court of Chancery Identifies Fiduciary Duties and Standard of Review for Controlling Stockholder

In a landmark decision, In re Sears Hometown & Outlet Stores, Inc. Stockholder Litigation,1 the Delaware Court of Chancery held that a controlling stockholder did not breach his fiduciary duties when he amended company bylaws...more

Delaware Books and Records Demands in 2023: Protections and Pitfalls for Companies

The past year saw significant developments in the Delaware courts for books and records inspection demands pursuant to Section 220. In a first-of-its-kind decision, the Court rejected an inspection demand as lacking a...more

Securities and Derivative Litigation: Quarterly Update - July 2023

Examine a major Ninth Circuit decision affirming dismissal of a Section 14(a) derivative action based on a forum-selection clause; Highlight the Third Circuit’s adoption of the Omnicare standard for securities fraud claims;...more

Delaware Court of Chancery Bars Stockholder from Inspecting Books and Records Related to Board’s ESG-Related Decision

Proof that an inspection demand is improperly “lawyer-driven” will overcome a stockholder’s pretextual claim for investigating wrongdoing. A stockholder does not have a proper purpose for investigating an “ordinary...more

Delaware Court of Chancery Offers Guidance on Enforceability of Contractual Waivers Not to Sue for Breach of Fiduciary Duty

Delaware Court of Chancery holds contractual waivers of fiduciary duties are facially valid when they are both narrowly tailored to authorize specific transactions and satisfy the Court’s review for reasonableness. Court...more

Delaware Court of Chancery Holds Corwin Cleansing Inapplicable to Board-Entrenching Actions

Court of Chancery holds that Corwin cleansing does not apply to claims seeking to enjoin entrenching actions subject to enhanced scrutiny review under Unocal. The Court found that Plaintiffs successfully pled facts...more

Delaware Court of Chancery Holds “MFW” Framework Applies to Controller Transaction Despite Substantially Higher Third-Party Offer

MFW protects controlling-stockholder transactions even when a third-party bidder makes a competing bid that is superior to a negotiated merger with the controller. A special committee will likely satisfy the duty of care...more

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