judicially created doctrine (Delaware) · Go Syfert
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judicially created doctrine in Delaware

10 Delaware opinions name it 2 courts 1955–2022 2 in the last five years

The cases below were cited by Delaware courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Plummer & Co. Realtors v. Crisafigreen
delsuperct · 1987 · cited in 1 Delaware opinions naming this issue, 2022–2022
1 sentence

2022In Mobil Oil Corp. v. Advanced Environmental Recycling Technologies, Inc., a federal court applying Delaware law opined that “the Supreme Court of Delaware would not recognize the fiduciary shield as an absolute bar to personal jurisdiction over a corporate employee.”65 The court reasoned that the out-of-state authorities relied on in Plummer had been called into question in their own jurisdictions and that they resulted in a construction that “would run counter to the expansive interpretation that Delaware courts have consistently 62 533 A.2d 1242, 1246 (Del.

11
Levinson v. Delaware Compensation Rating Bureau, Inc.green
del · 1992 · cited in 1 Delaware opinions naming this issue, 2020–2020
1 sentence

2020Rating Bureau, Inc., 616 A.2d 1182, 1187 (Del. 1992), which this Opinion will refer to as the “Finality Doctrine.” As the Delaware Supreme Court has explained the doctrine: A judicially created rule, the doctrine requires that where a remedy before an administrative agency is provided, relief must be sought by exhausting this remedy before the courts will either review any action by the agency or provide an independent remedy.

11
Pack & Process, Inc. v. Celotex Corp.green
delsuperct · 1985 · cited in 1 Delaware opinions naming this issue, 2020–2020
1 sentence

2020July 1, 2010) (citing Pack & Process, Inc. v. Celotex Corp., 503 A.2d 646, 658 (Del.Super.1985)). 21 Consumer Fraud Act is a legislative creation whereas the economic loss doctrine is judicially created.103 Absent a constitutional violation, and in the absence of any authority, the Court will not apply a judicially created doctrine over legislation.104 This claim also survives.

11
Grimes v. DSC Communications Corp.green
delch · 1998 · cited in 1 Delaware opinions naming this issue, 2018–2018
1 sentence

2018The Garner Exception The Garner exception is a judicially created doctrine founded on the recognition that “where the corporation is in suit against its stockholders on charges of acting inimically to stockholder interests, protection of those interests as well as those of the corporation and of the public require that the availability of the privilege be subject to the right of the stockholders to show ‘good cause’ why the privilege should not apply.”42 A corporation invokes the attorney-client privilege through its officers and directors; those individuals owe a duty as fiduciaries to the st

11
Lambrecht v. O'NEALgreen
del · 2010 · cited in 1 Delaware opinions naming this issue, 2014–2014
1 sentence

2014Lambrecht v. O’Neal, 3 A.3d 277, 284 (Del.2010).

11
Epstein v. Chatham Park, Inc.green
delsuperct · 1959 · cited in 1 Delaware opinions naming this issue, 1985–1985
1 sentence

1985See Epstein v. Chatham Park, Inc., Del.Super., 153 A.2d 180, 184 (1959).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Delaware. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Layton v. Hudson neutral
delsuperct · 1911
2 sentences

1955Layton v. Hudson, 2 Boyce 573 , 83 A. 134 ; Petrucci v. Landon, Del.Super., 107 A.2d 236 .

1955Layton v. Hudson, 2 Boyce 573 , 83 A. 134 ; Petrucci v. Landon, Del.Super., 107 A.2d 236 .

21955–1955
Petrucci v. Landon green
delsuperct · 1954
2 sentences

1955Layton v. Hudson, 2 Boyce 573 , 83 A. 134 ; Petrucci v. Landon, Del.Super., 107 A.2d 236 .

1955Layton v. Hudson, 2 Boyce 573 , 83 A. 134 ; Petrucci v. Landon, 9 Terry 491, 107 A.2d 236 .

21955–1955
Schoon v. Smith green
del · 2008
2 sentences

2022As the court observed, the doctrine gained greater significance during the industrial revolution, when the “individual stockholder was in need of a means of invoking judicial power to curb managerial abuse.”37 Because equitable standing is a judicially-created doctrine, the court reasoned that it could be “judicially extended to address new circumstances.” 38 The court further reasoned that a doctrine born of necessity should be extended more broadly only to address the animating need—“preventing injustice where it is apparent that material corporate rights would not otherwise be protected.”39

2022As the court observed, the doctrine gained greater significance during the industrial revolution, when the “individual stockholder was in need of a means of invoking judicial power to curb managerial abuse.”37 Because equitable standing is a judicially-created doctrine, the court reasoned that it could be “judicially extended to address new circumstances.” 38 The court further reasoned that a doctrine born of necessity should be extended more broadly only to address the animating need—“preventing injustice where it is apparent that material corporate rights would not otherwise be protected.”39

12022–2022
cluster 291747 green
ca1 · 1970
1 sentence

2018Ch. 1998) (quoting Garner, 430 F.2d at 1103–04). 43 Zirn, 621 A.2d at 781 . 10 “management has a legitimate concern that its confidential communications should be allowed to remain confidential.”44 Thus, the Garner exception balances “the privilege’s purpose of encouraging open communication between counsel and client [against] . . . the right of a stockholder to understand what advice was given to fiduciaries who are charged with breaching their duties.”45 Our Supreme Court has described the Garner exception as “narrow, exacting, and intended to be very difficult to satisfy.”46 Garner provide

12018–2018
Zirn v. VLI Corp. green
del · 1993
1 sentence

2018Ch. 1998) (quoting Garner, 430 F.2d at 1103–04). 43 Zirn, 621 A.2d at 781 . 10 “management has a legitimate concern that its confidential communications should be allowed to remain confidential.”44 Thus, the Garner exception balances “the privilege’s purpose of encouraging open communication between counsel and client [against] . . . the right of a stockholder to understand what advice was given to fiduciaries who are charged with breaching their duties.”45 Our Supreme Court has described the Garner exception as “narrow, exacting, and intended to be very difficult to satisfy.”46 Garner provide

12018–2018
Kessler v. Armstrong Cork Co. green
ca2 · 1907
1 sentence

1958He argues, however, that under a judicially created rule Holland will give binding effect to a foreign judgment under some circumstances and that plaintiffs have failed to sustain their burden of showing that under Dutch law binding effect would not be given to a Delaware determination, citing Kessler v. Armstrong Cork, 2 Cir., 158 F. 744 (there was no offer in this case to prove the foreign law concerning foreign judgments); Gull v. Constam, D.C., 105 F.Supp. 107 (held that absence of reciprocity must be pleaded by one relying upon it).

11958–1958
Gull v. Constam green
cod · 1952
1 sentence

1958He argues, however, that under a judicially created rule Holland will give binding effect to a foreign judgment under some circumstances and that plaintiffs have failed to sustain their burden of showing that under Dutch law binding effect would not be given to a Delaware determination, citing Kessler v. Armstrong Cork, 2 Cir., 158 F. 744 (there was no offer in this case to prove the foreign law concerning foreign judgments); Gull v. Constam, D.C., 105 F.Supp. 107 (held that absence of reciprocity must be pleaded by one relying upon it).

11958–1958

Where else courts name it

CA 303 (1955–2026) IL 124 (1966–2026) MI 83 (1976–2026) PA 79 (1961–2024) TX 79 (1969–2022) MO 77 (1986–2025) LA 76 (1960–2025) OH 72 (1978–2026) WI 54 (1997–2025) MD 53 (1962–2022) NJ 50 (1976–2026) WA 47 (1973–2025) FL 41 (1983–2024) CO 38 (1983–2025) VA 35 (1974–2026) UT 33 (1981–2023) NM 29 (1978–2023) NY 28 (1959–2024) CT 27 (1994–2024) KS 24 (1983–2022) MA 23 (1976–2019) ME 21 (1977–2025) TN 20 (1981–2024) GA 20 (1981–2025) MS 17 (1979–2024) MN 17 (1985–2024) ID 17 (1966–2026) NH 17 (1965–2020) AZ 15 (1980–2023) RI 15 (1979–2022) OR 14 (1996–2024) AL 14 (1984–2024) WY 13 (1981–2026) IN 11 (1980–2023) DE 10 (1955–2022) AK 9 (1980–2019) OK 9 (1985–2014) VT 8 (1989–2026) WV 8 (1981–2020) AR 7 (1997–2022) KY 7 (2004–2025) IA 7 (1995–2018) VI 7 (2009–2017) MT 6 (1980–2009) NC 6 (1991–2023) NE 4 (1996–2020) DC 4 (1999–2009) NV 4 (1979–2024) SC 4 (1975–2019) SD 3 (1957–1996) ND 2 (2013–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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