Barry Leistner v. Red Mud Enterprises LLC

CourtCourt of Chancery of Delaware
DecidedApril 25, 2024
DocketC.A. No. 2023-0503-SEM
StatusPublished

This text of Barry Leistner v. Red Mud Enterprises LLC (Barry Leistner v. Red Mud Enterprises LLC) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barry Leistner v. Red Mud Enterprises LLC, (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

BARRY LEISTNER, ) ) Plaintiff, ) ) v. ) C.A. No. 2023-0503-SEM ) RED MUD ENTERPRISES LLC, ) ) Defendant. )

ORDER GRANTING IN PART MOTION FOR FEES

WHEREAS, on May 8, 2023, Barry Leistner (the “Plaintiff”) brought an

action seeking inspection of books and records against Red Mud Enterprises LLC

(the “Defendant”); 1

WHEREAS, in an oral final report, I recommended that judgment be entered

in favor of the Defendant; 2 on exceptions, Vice Chancellor Glasscock adopted and

affirmed my report; 3

WHEREAS, the Defendant first requested fee shifting in its June 5, 2023

answer; 4 the Defendant reiterated its fee request in its November 7, 2023 motion for

1 Docket Item (“D.I.”) 1. This order is limited to the posture and background necessary to address the fee request; interested readers are directed to my final report and Vice Chancellor Glasscock’s adopting letter decision for additional predicate. D.I. 78, 98. 2 D.I. 78. 3 D.I. 98. 4 D.I. 13.

1 fees and expenses (the “Motion”); 5 the Defendant seeks shifting under Section 13.15

of its LLC agreement (the “Provision”), which provides:

In the event that any party hereto institutes any legal suit, action or proceeding, including arbitration, against another party in respect of a matter arising out of or relating to this Agreement, the prevailing party in the suit, action or proceeding shall be entitled to receive, in addition to all other damages to which it may be entitled, the costs incurred by such party in conducting the suit, action or proceeding, including reasonable attorneys’ fees and court costs[;] 6

WHEREAS, the Plaintiff opposes shifting, arguing (1) the Provision only

applies to one of the Plaintiff’s three claims in its complaint (the claim arising from

the LLC agreement (“Count II”) and not the claims brought under 6 Del. C. § 18-

305 (“Count I”) and a letter agreement (“Count III”)); (2) this Court should, thus,

reduce the fees proportionally; (3) equity requires further fee reduction or denial

under the circumstances; and (4) the Defendant’s Rule 88 affidavit is not sufficiently

detailed; 7

WHEREAS, the Motion was fully briefed on January 10, 2024; 8

WHEREAS, contractual fee shifting provisions are an exception to the

American Rule that litigants are responsible for their own fees and expenses; 9 “[a]

5 D.I. 93. 6 Id. 7 D.I. 105. 8 D.I. 106. 9 Braga Inv. & Advisory, LLC v. Yenni, 2023 WL 3736879, at *18 (Del. Ch. May 31, 2023).

2 fee-shifting provision must be a clear and unequivocal agreement triggered by a

dispute over a party’s failure to fulfill obligations under the contract. It must include

specific language, such as any reference to ‘prevailing parties,’ a hallmark term of

fee-shifting provisions[;]”10 when a contractual fee shifting provision does not

define “prevailing party,” the Court must supply the meaning; 11 generally, a

prevailing party is the party that “predomina[tes] in the litigation[;]” 12 “to achieve

predominance, a litigant should prevail on the case’s ‘chief issue[;]’” 13

WHEREAS, “under Delaware law, the term ‘arising out of’ is broadly

construed to require some meaningful linkage between the two conditions imposed

in the contract[;]” 14 “[a]bsent any qualifying language that fees are to be awarded

claim-by-claim or on some other partial basis, a contractual provision entitling the

prevailing party to fees will usually be applied in an all-or-nothing manner[;]”15

10 Murfey v. WHC Ventures, LLC, 2022 WL 214741, at *2 (Del. Ch. Jan. 25, 2022) (citations and quotations omitted). 11 See Mrs. Fields Brand, Inc. v. Interbake Foods LLC, 2018 WL 300454, at *2 (Del. Ch. Jan. 5, 2018) (citing Brandin v. Gottlieb, 2000 WL 1005954, at *26 (Del. Ch. July 13, 2000)). 12 Comrie v. Enterasys Networks, Inc., 2004 WL 5366650, at *2 (Del. Ch. Apr. 27, 2004). 13 Bako Pathology LP v. Bakotic, 288 A.3d 252, 281 (Del. 2022) (quoting 2009 Caiola Fam. Tr. v. PWA, LLC, 2015 WL 6007596, at *33 (Del. Ch. Oct. 15, 2015)). 14 Pac. Ins. Co. v. Liberty Mut. Ins. Co., 956 A.2d 1246, 1257 (Del. 2008). 15 Aloha Power Co. v. Regenesis Power, LLC, 2017 WL 6550429, at *5 (Del. Ch. Dec. 22, 2017) (citations omitted).

3 WHEREAS, in opposing fee shifting in full, the Plaintiff points to a few

exceptional cases:

• In PharmAthene, Inc. v. SIGA Technologies, Vice Chancellor Parsons limited contractual fee shifting due to the prevailing party’s split of its claims into equal parts.16 On appeal, the Delaware Supreme Court affirmed that fees should be shifted but reversed and remanded the fee award for reconsideration in light of the Supreme Court’s reversal of the Court’s overall damages award.17 On remand, Vice Chancellor Parsons increased the proportion of fees to be shifted to the prevailing party.18 • In Great American Opportunities, Inc. v. Cherrydale Fundraising, LLC, Vice Chancellor Parsons limited statutory fee shifting given the multiple claims at issue. 19 Because only one of two claims was subject to statutory fee shifting and the two claims “have received essentially equal billing[,]” only half of the overall fees were shifted.20 • Finally, in Council of Dorset Condominium Apartments v. Gordon, Vice Chancellor Lamb declined to shift fees under contractual fee shifting where both parties prevailed on portions of their claims, any fee shifting would be limited by the claims on which each side prevailed, those fees would offset each other, and the plaintiff initiated the dispute in a “high-handed manner” and “the interests of justice opposed shifting fees.” 21

16 PharmAthene, Inc. v. SIGA Techs., Inc., 2011 WL 4390726, at *44 (Del. Ch. Sept. 22, 2011), judgment entered, 2012 WL 2308180 (Del. Ch. May 31, 2012), aff’d in part, rev’d in part and remanded, 67 A.3d 330 (Del. 2013), and aff’d in part, rev’d in part, 67 A.3d 330 (Del. 2013). 17 SIGA Techs., Inc. v. PharmAthene, Inc., 67 A.3d 330, 352 (Del. 2013). 18 PharmAthene, Inc. v. SIGA Techs., Inc., 2014 WL 3974167, at *19 (Del. Ch. Aug. 8, 2014). 19 Great Am. Opportunities, Inc. v. Cherrydale Fundraising, LLC, 2010 WL 338219, at *29 (Del. Ch. Jan. 29, 2010). 20 Id. 21 Council of Dorset Condo. Apartments v. Gordon, 2002 WL 1335620, at *1–2 (Del. Ch. June 14, 2002), aff’d, 820 A.2d 371 (Del. 2002).

4 WHEREAS, conversely, in Brandin v. Gottlieb, then-Vice Chancellor Strine

interpreted a contractual fee shifting provision that entitled a prevailing party to “all

of its reasonable legal fees and disbursements” as “eschew[ing] a claim-by-claim

approach by failing to insert any language in the contract that would authorize the

court to exercise discretion to award less than ‘all’ the prevailing party’s fees in a

case where the prevailing party had achieved a less than full victory[;]”22 thus, the

Court shifted all fees in favor of the party who prevailed on most of her claims; 23

WHEREAS, under Court of Chancery Rule 88, “the Court shall require [fee]

applicant[s] to make an affidavit or submit a letter, as the Court may direct, itemizing

(1) the amount which has been received, or will be received, for that purpose from

any source, and (2) the expenses incurred and services rendered, before making such

an allowance[;]”

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cohen v. Cohen
269 A.2d 205 (Supreme Court of Delaware, 1970)
Pacific Insurance Co. v. Liberty Mutual Insurance
956 A.2d 1246 (Supreme Court of Delaware, 2008)
SIGA Technologies, Inc. v. PharmAthene, Inc.
67 A.3d 330 (Supreme Court of Delaware, 2013)
Edgewater Growth Capital Partners LP v. H.I.G. Capital, Inc.
68 A.3d 197 (Court of Chancery of Delaware, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Barry Leistner v. Red Mud Enterprises LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barry-leistner-v-red-mud-enterprises-llc-delch-2024.