Enhabit, Inc. v. Nautic Partners IX, L.P.

Court of Chancery of Delaware·Decided May 14, 2025·No. 2022-0837-LWW·Published

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

ENHABIT, INC., ADVANCED ) HOMECARE MANAGEMENT, ) LLC, and ENCOMPASS HEALTH ) CORPORATION, ) ) Plaintiffs, ) ) v. ) C.A. No. 2022-0837-LWW ) NAUTIC PARTNERS IX, L.P., ) NAUTIC PARTNERS, LLC, ) CHRISTOPHER COREY, VISTRIA ) FUND III, LP, THE VISTRIA ) GROUP, LP, DAVID SCHUPPAN, ) TVG NP HOMECARE TOPCO, LP, ) and CHRIS A. WALKER, ) ) Defendants. )

ORDER GRANTING CONSTRUCTIVE TRUST

WHEREAS, Plaintiffs Enhabit, Inc. (“Enhabit”), Advanced Homecare

Management, LLC (“Advanced Homecare”), and Encompass Health Corporation

(“EHC” and, together with Enhabit and Advanced Homecare, “Plaintiffs”) filed

their Amended Complaint in the above-captioned action on February 7, 2023;

WHEREAS, the Amended Complaint alleged a claim for “Aiding and

Abetting Anthony’s Breaches of Fiduciary Duty” against all Defendants in Count I;

WHEREAS, the Amended Complaint alleged a claim for “Breach of

Fiduciary Duty” against Defendant Chris A. Walker (“Walker”) in Count II; WHEREAS, the Amended Complaint alleged a claim for “Aiding and

Abetting Walker’s Breaches of Fiduciary Duty” against Defendants Nautic

Partners IX, L.P. and Nautic Partners, LLC (together, “Nautic”), Defendants

Vistria Fund III, LP and The Vistria Group, LP (together, “Vistria” and, with Nautic,

the “PE Defendants”), Defendant Christopher Corey, Defendant David Schuppan,

and Defendant TVG NP Homecare Topco, LP (“Topco”) in Count III;

WHEREAS, the Amended Complaint alleged a claim for “Breach of

Contract” against Walker in Count IV, which was subsequently dismissed;

WHEREAS, the Amended Complaint alleged a claim for “Joint Venture

Liability” against the PE Defendants in Count V;

WHEREAS, the Amended Complaint alleged a claim for “Unjust

Enrichment” against all Defendants in Count VI;

WHEREAS, a seven-day trial was held from December 11, 2023 to December

19, 2023 on Counts I-III and V-VI;

WHEREAS, on December 2, 2024, the Court issued a memorandum opinion

(the “Opinion”) entering judgment for Plaintiffs on Counts I, II, and III and deeming

Counts V and VI moot;

WHEREAS, on December 9, 2024, Defendants filed a Motion for

Reargument and For Clarification (“Motion for Reargument”) seeking reargument,

withdrawal, or clarification of the remedy imposed in the Opinion;

2 WHEREAS, on February 18, 2025, the Court issued a letter opinion (“Letter

Opinion” and together with the Opinion, the “Opinions”) denying Defendants’

Motion for Reargument, but issuing a clarification as to the funds subject to the

constructive trust per the Opinion;

WHEREAS, the Opinions required the parties to file a proposed form of order

outlining the formation of a constructive trust, the function of the trust, and the role

and authority of the trustee, consistent with the Opinions; and

WHEREAS, the Court has duly considered the proposed orders submitted by

the parties;

WHEREAS, concurrently with this Order Granting Constructive Trust (the

Order”), the Court has issued a letter opinion explaining the reasoning in resolving

certain substantive disputes in the parties’ competing proposed orders;

NOW, THEREFORE, IT IS ORDERED, this 14th day of May, 2025, as

follows:

I. PROPERTY SUBJECT TO CONSTRUCTIVE TRUST

1. All Proceeds (as defined below), if any, will be held in a constructive

trust (the “Constructive Trust”) to be disbursed on the instructions of the Trustee

appointed pursuant to this Order or as otherwise ordered by this Court.

2. As used herein, the following terms have the meanings set forth below:

3 a. “Dilutive Issuance” means any issuance of equity

interests (or options, warrants or other securities that are directly or

indirectly convertible into, or exercisable or exchangeable for equity

interests) in Topco to any person; provided that any issuances to

officers, employees and/or directors of Topco or its subsidiaries as part

of compensation or similar arrangements entered into in compliance

with this Order do not constitute Dilutive Issuances.

b. “Disposition” means any sale, exchange, conveyance,

transfer or other disposition of an interest in an asset by any means

whatsoever (including by merger, consolidation or similar transaction).

c. “Proceeds” means the aggregate amount of (a) proceeds

(whether in the form of cash, securities or other property, tangible or

intangible) received by Topco and available for dividends or other

distributions to Topco’s equity investors; and (b) without duplication

of the foregoing, any payment received by a Defendant other than

Topco resulting from any sale or other transfer of direct or indirect

equity interests in Topco, provided that the Specified Percentage be

reduced to take into account the percentage of total outstanding

interests so sold or transferred. For the avoidance of doubt, Proceeds

does not include amounts that Topco contributes or otherwise disburses

4 or sets aside for (a) payments in respect of debt of Topco or any of its

subsidiaries, including payments on debt-like preferred stock issued to

April Anthony by Topco subsidiaries to refinance its term debt in

March 2023, (b) reasonable, customary and documented out-of-pocket

transaction costs and expenses incurred by Topco payable to

unaffiliated third parties in connection with the transaction or event

giving rise to such proceeds, or (c) contributions to Topco or any of its

subsidiaries for use in the operation of or growth of the business

conducted by Topco and its subsidiaries (including in support of

anticipated acquisitions).

d. “Specified Percentage” means, initially, the total amount

of forty-three percent (43%). In the event of the consummation of a

Dilutive Issuance or Disposition of an equity interest in Topco by a

Defendant other than Topco, the Specified Percentage applicable to

Proceeds received by Topco shall be adjusted as set forth in the Section

of this Order entitled “Dilution.”

II. PAYMENT OBLIGATION

3. On the date of the entry of this Order, Defendants must deliver to

Plaintiffs, the Trustee (as defined below), and the Court a sworn statement setting

forth the amount of any Proceeds received by Defendants since May 18, 2021 (other

5 than any Proceeds received by Defendants from their Disposition of Topco equity

interests to April Anthony for approximately $87 million in 2022), along with

reasonably detailed supporting calculations and such other related information as the

Trustee may reasonably request. Within 14 days of the entry of this Order,

Defendants must pay to the Trustee an amount equal to such Proceeds, and the

Trustee will promptly pay to Plaintiffs the Specified Percentage of such Proceeds

and remit the remainder to Defendants.

4. Without duplication of any amounts owed under the immediately

preceding paragraph, Topco or other Defendants in receipt of Proceeds must, within

14 days of the receipt thereof: (a) pay to the Trustee an amount equal to such

Proceeds; and (b) provide notice to the Trustee and Plaintiffs of (i) the amount of

Proceeds subject to the Constructive Trust, (ii) the calculation used to determine the

amount of such Proceeds, (iii) a calculation of Plaintiffs’ portion of the Proceeds,

applying the Specified Percentage, and (iv) proposed instructions (including a flow

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Enhabit, Inc. v. Nautic Partners IX, L.P., (Del. Ct. App. 2025).

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