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United States Leading Case derivative claimsderivative claims shareholder

Aronson v Lewis

473 A.2d 805 (Del. 1984)
JurisdictionUnited States
CourtDelaware Supreme Court
Year1984
StatusBinding authority

Summary

Establishes the two-prong test for demand futility in shareholder derivative actions: whether the board is disinterested and independent, and whether the challenged transaction is protected by the business judgment rule.

Key Principle

demand futility two-prong test for derivative actions

Area of Law

Delaware Corporate Law

Related Cases

Corwin v KKR Financial Holdings LLC 125 A.3d 304 (Del. 2015)

Fully informed and uncoerced stockholder approval of a non-controller transaction cleanses it of fiduciary challenge and applies business judgment review.

Kahn v M&F Worldwide Corp 88 A.3d 635 (Del. 2014)

Under Delaware law, a controlling shareholder merger conditioned ab initio on both special committee approval and majority-of-minority vote earns business judgment review rather than entire fairness scrutiny.

In re Caremark International Inc Derivative Litigation 698 A.2d 959 (Del. Ch. 1996)

Directors must implement adequate information and reporting systems to satisfy their fiduciary duty of oversight; failure to do so may constitute a breach of duty.

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