6 Nevada opinions name it 1 courts 2017–2025 3 in the last five years
The cases below were cited by Nevada 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.
| Case | Followed | Cited |
|---|---|---|
Cohen v. Mirage Resorts, Inc.green2 sentences2024PAMTP did not plead a direct claim “A derivative claim is one brought by a shareholder on behalf of the corporation to recover for harm done to the corporation.” Parametric I, 133 Nev. at 423, 401 P.3d at 1105 (emphasis added) (quoting Cohen v. Mirage Resorts, Inc., 119 Nev. 1, 19 , 62 P.3d 720, 732 (2003)). 2024PAMTP did not plead a direct claim “A derivative claim is one brought by a shareholder on behalf of the corporation to recover for harm done to the corporation.” Parametric I, 133 Nev. at 423, 401 P.3d at 1105 (emphasis added) (quoting Cohen v. Mirage Resorts, Inc., 119 Nev. 1, 19 , 62 P.3d 720, 732 (2003)). | 3 | 4 |
Tooley v. Donaldson, Lufkin, & Jenrette, Inc.green2 sentences2025Under Tooley, to plead a direct claim, "Mlle stockholder must demonstrate that the duty breached was owed to the stockholder and that he or she can prevail without showing an injury to the corporation." Id. at 1039 . 2017We thus take this opportunity to clarify Cohen and distinguish between direct and derivative claims by adopting the direct harm test, as articulated in Tooley v. Donaldson, Lufkin & Jenrette, Inc., 845 A.2d 1031, 1033 (Del. 2004), which allows a direct claim when shareholder injury is independent from corporate injury. | 2 | 3 |
Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc.green2 sentences2024Supreme Court OF NEVADA (0) 19370 aE os Supreme Court OF NevADA (OV 1947 Sine Forbes Holdings, Inc., 506 A.2d 173, 182 (1986), “already provides for a direct claim.”! 2024SUPRENIE COURT OF NEVADA 9 0.5) 1947/1 426)0 • Forbes Holdings, Inc., 506 A.2d 173, 182 (1986), "already provides for a direct claim." Brookfield, 261 A.3d at 1266-67. | 2 | 2 |
Lipton v. News International, Plcgreen2 sentences2017"A special injury is a wrong that is separate and distinct from that suffered by other shareholders, or a wrong involving a contractual right of a shareholder, such as the right to vote, or to assert majority control, which exists independently of any right of the corporation." Id. (internal quotation marks omitted); see also Lipton v. News Ina Plc, 514 A.2d 1075, 1078 (Del. 1986) ("[A] plaintiff alleges a special injury and may maintain an individual action if he complains of an injury distinct from that suffered by other shareholders or a wrong involving one of his contractual rights as a sh 2017"A special injury is a wrong that is separate and distinct from that suffered by other shareholders, or a wrong involving a contractual right of a shareholder, such as the right to vote, or to assert majority control, which exists independently of any right of the corporation." Id. (internal quotation marks omitted); see also Lipton v. News Ina Plc, 514 A.2d 1075, 1078 (Del. 1986) ("[A] plaintiff alleges a special injury and may maintain an individual action if he complains of an injury distinct from that suffered by other shareholders or a wrong involving one of his contractual rights as a sh | 2 | 2 |
Wyre v. Stategreen1 sentence2025Id. at 799; cf Actiuision, 124 A.3d at 1049-50 (noting that an alleged infringernent of a shareholder's voting rights ordinarily constitutes a direct claim). | 1 | 1 |
Small v. Fritz Companies, Inc.green1 sentence2019In Small, the California Supreme Court held that California law authorizes a direct, as opposed to derivative, claim to a shareholder who alleges that they were wrongfully induced to hold stock instead of selling it. 65 P.3d at 1260, 1266 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Nevada. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re Williams
green
1 sentence2019In Citigroup Inc. v. AHW Investment Partnership, 140 A.3d 1125 (Del. 2016), the Delaware Supreme Court emphasized that difficulties proving a holder claim do not affect its status as a direct claim, and further noted that purchaser claims are direct as well: SUPREME COURT OF NEVADA 4 tO) 1947A Finally, whatever analytical problems are involved in recognizing the Holder Claims as a species of common law fraud claim or negligent misrepresentation claim do not turn those Holder Claims into claims belonging to the issuer who is the primary defendant, or into claims governed by the internal affairs | 1 | 2019–2019 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.