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United States Leading Case no conflict ruleno profit rule

Meinhard v Salmon

164 N.E. 545 (NY 1928)
JurisdictionUnited States
CourtNew York Court of Appeals
Year1928
StatusBinding authority

Summary

Joint venturers owe each other the highest fiduciary duty — the 'punctilio of an honor the most sensitive' — requiring full disclosure of business opportunities arising from the venture.

Key Principle

Cardozo's "punctilio of an honor the most sensitive" fiduciary standard; widely cited beyond NY

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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