Bryan Dorsey v. Robert T. Jones

CourtCourt of Chancery of Delaware
DecidedSeptember 8, 2025
Docket2024-0134-CDW
StatusPublished

This text of Bryan Dorsey v. Robert T. Jones (Bryan Dorsey v. Robert T. Jones) 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
Bryan Dorsey v. Robert T. Jones, (Del. Ct. App. 2025).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE CHRISTIAN DOUGLAS WRIGHT LEONARD L. WILLIAMS JUSTICE CENTER MAGISTRATE IN CHANCERY 500 NORTH KING STREET, SUITE 11400 WILMINGTON, DE 19801-3734

September 8, 2025

Rudolf Koch, Esquire Robert T. Jones Travis S. Hunter, Esquire 2925 Bookhout Street Gabriela Z. Monasterio, Esquire Dallas, TX 75201 Richards, Layton & Finger, P.A. One Rodney Square 920 North King Street Wilmington, DE 19801

Re: Bryan Dorsey, et al. v. Robert T. Jones, C.A. No. 2024-0134-CDW

Dear Counsel and Party:

Through this letter, the court resolves eight pending motions filed by

defendant and counterclaim plaintiff Robert Jones (“Jones”).1 This action has

been given heavy attention from the parties and the court over the past 18

1 Mot. for Summ. J. for Indemnification and Advancement of Legal Fees Pursuant to Del. Gen. Corp. Law § 145, Docket Item (“D.I.”) 67; Mot. for Entry of Default Pursuant to R. 55(a), D.I. 86; Mot. to Confirm Interpleader of Funds by JPMorgan Chase Bank, N.A., D.I. 87; Mot. to Expedite and Req. for Immediate Status Conf., D.I. 88; Mot. to Strike Mot. to Dismiss as Defective and Unauthorized, D.I. 89; Mot. to Disqualify Couns. and Notice of Cross-Matter Ethical Conflict, D.I. 91; Mot. to Pres. and Produc. Representation and Conflict Mat’ls, D.I. 91; Mot. to Dismiss Deriv. Claims for Lack of Standing, D.I. 92. C.A. No. 2024-0134-CDW September 8, 2025 Page 2 of 17

months, so the court dispenses with a general factual recitation and proceeds

directly to the motions.

Motion to Dismiss Derivative Claims for Lack of Standing (D.I. 92)

Jones moves to dismiss the amended complaint2 because, he says,

Dorsey lacks standing to assert derivative claims on behalf of nominal

defendant Roots Food Group Holdings, Inc. (“Company”).3 Jones asserts that

because Dorsey “has granted an irrevocable proxy under 8 Del. C. § 212 to

Jones over all shares under his control, . . . [he] cannot maintain standing to

prosecute a derivative action where he has no shareholder authority.”4

According to Jones,

[t]he shareholder agreement expressly requires all Founding Holders to grant proxy to Jones as a condition of receiving shares. That proxy, coupled with an interested governed by 8 Del. C. § 212, remain valid and enforceable. Dorsey lacks

2 Verified Am. Compl. for Breach of Fid. Duty, Unjust Enrichment, and Conversion, D.I. 20 (“Am. Compl.”). 3 Mot. to Dismiss Deriv. Claims for Lack of Standing, D.I. 92 (“Deriv. Dismissal Mot.”), ¶¶ 3–6. Jones actually brings this motion against both Jones and Roots Group Holdings LLC (“HoldCo”). See id. at 1; ¶ 2. The only claims HoldCo asserts are direct claims against Jones for conversion and unjust enrichment. See Am. Compl. ¶¶ 121–26 (conversion), ¶¶ 127–129 (unjust enrichment). Because HoldCo is not asserting any derivative claims on behalf of the Company, the court denies the Derivative Dismissal Motion as to HoldCo. 4 Deriv. Dismissal Mot. ¶ 3. C.A. No. 2024-0134-CDW September 8, 2025 Page 3 of 17

authority to override this agreement or act in contravention of the granted proxy.5

Jones cites no case law in support of this argument.

Jones’ argument is plainly incorrect. “A proxy is evidence of an agent’s

authority to vote shares owned by another.” Eliason v. Englehart, 733 A.2d

944, 946 (Del. Ch. 1999) (citing Duffy v. Loft, Inc., 151 A. 223 (Del. Ch.

1930), aff’d, 152 A. 849 (Del. 1930)). As the court explained in Hawkins v.

Daniel:

The owner of shares acts as principal to grant agency power to the proxyholder. The proxyholder agrees to exercise the authority conferred under the proxy arrangement in accordance with its terms and the proxyholder’s fiduciary duties as agent.

273 A.3d 792, 808 (Del. Ch. 2022) (citations omitted). Here, Dorsey’s grant

of proxy defines its scope, giving Jones the power “to vote and act on

[Dorsey’s] behalf and in [Dorsey’s] name, place and stead with respect to

[Dorsey’s] Company Securities.”6 The proxy may be exercised “at any

annual, special or other meeting of the stockholders of the Company, and at

any adjournment of any such meeting, held during the term of this Agreement

5 Id. ¶ 5. 6 D.I. 92 Ex. A § 3.2. C.A. No. 2024-0134-CDW September 8, 2025 Page 4 of 17

and to act by written consent with respect to [Dorsey’s] Company

Securities[.]”7

The proxy agreement separates the voting rights in Dorsey’s shares

from the economic interest in them. That is all. It does not eliminate Dorsey’s

status as a stockholder of Roots; he still owns his shares. Nor does the proxy

purport to require Dorsey to obtain Jones’ permission to initiate derivative

litigation on behalf of Roots. The motion to dismiss is denied on this basis.8

At the end of his motion, Jones alleges dismissal of the Amended

Complaint is also justified because Dorsey and HoldCo have acted with

unclean hands.9 This argument also fails.

7 Id. 8 The court notes that Dorsey’s only claim against Jones in the Amended Complaint (Count I, for breach of fiduciary duties) is presented as an alternative to the Company asserting the same claim directly. See Am. Compl. 28 n.8 (“All claims are now brought directly by the Company, but Dorsey remains as a plaintiff to raise the claims derivatively in the alternative to avoid Jones attempting to improperly remove Dorsey as a director of the Company and move to dismiss the counts on behalf of the Company. While Jones is precluded from doing so by the 225 Order, plaintiffs nevertheless bring these claims directly and derivatively out of an abundance of caution.”). A ruling that Dorsey cannot assert Count I derivatively would not prevent Count I from going forward because Jones has not moved to dismiss Count I as a direct claim by the Company. 9 Deriv. Dismissal Mot. ¶ 7. C.A. No. 2024-0134-CDW September 8, 2025 Page 5 of 17

The doctrine of unclean hands can be raised by litigants as an

affirmative defense.10 Like other affirmative defenses, unclean hands is an

awkward dance partner for a motion to dismiss. The party asserting an

affirmative defense bears the burden of proving it,11 and the facts necessary to

prove an affirmative defense are often not pleaded in a complaint—which is

typically the only document the court can refer to when deciding a motion to

dismiss.12 Thus, “[u]nless it is clear from the face of the complaint that an

affirmative defense exists and that the plaintiff can prove no set of facts to

avoid it, dismissal of the complaint based upon an affirmative defense is

inappropriate.” Stephen G. Perlman, Rearden LLC v. Vox Media, Inc., 2015

10 See, e.g., New Start Hldgs., LLC v. Zhou, 2024 WL 4039440, at *14 (Del. Ch. Sept. 4, 2024) (“Defendants invoked the doctrine of unclean hands as an affirmative defense.”) (citation omitted); Claros Diagnostics, Inc. S’holders Rep. Comm. ex rel. Goldberg v. OPKO Health, Inc., 2020 WL 829361, at *12–13 (Del. Ch. Feb. 19, 2020) (evaluating the doctrine of unclean hands as an affirmative defense); cf. id. (“Typically, . . . application of unclean hands is based upon a developed factual record.”) (citing Stone & Paper Invs., LLC v. Blanch, 2019 WL 2374005, at *9 (Del. Ch. May 31, 2019)). 11 Desktop Metal, Inc. v. Nano Dimension Ltd., 2025 WL 904521, at *22 (Del. Ch. Mar. 24, 2025) (“[A] party asserting an affirmative defense bears the burden of proof.”) (citing Lighthouse Behav. v. Milestone Addiction, 2023 WL 3486671, at *9 (Del. Ch. May 17, 2023)). 12 In re Gardner Denver, Inc., 2014 WL 715705, at *2 (Del. Ch. Feb. 21, 2014); Hudson v. Wesley Coll., Inc., 1993 WL 525519, at *1 (Del. Ch. Nov. 19, 1993). C.A. No.

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Bryan Dorsey v. Robert T. Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryan-dorsey-v-robert-t-jones-delch-2025.