In re Sears Hometown and Outlet Stores, Inc. Stockholder Litigation

Court of Chancery of Delaware·Decided March 21, 2025·No. C.A. No. 2019-0798-JTL·Published

Opinion

EFiled: Mar 21 2025 08:00AM EDT Transaction ID 75906213 Case No. 2019-0798-JTL IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

IN RE SEARS HOMETOWN AND OUTLET ) CONSOLIDATED STORES, INC. STOCKHOLDER LITIGATION ) C.A. No. 2019-0798-JTL

MEMORANDUM OPINION DECLINING TO CERTIFY INTERLOCUTORY APPEAL

Date Submitted: March 12, 2025 Date Decided: March 21, 2025

Thomas A. Uebler, Brian V. DeMott, Terisa A. Shoremount, MCCOLLOM D’EMILIO SMITH UEBLER LLC, Wilmington, Delaware; Counsel for Cannon Square, LLC

Ned Weinberger, Mark Richardson, Michael C. Wagner, Jiahui (Rose) Wang, LABATON KELLER SUCHAROW LLP, Wilmington, Delaware; Peter B. Andrews, Craig J. Springer, David M. Sborz, Christopher P. Quinn, ANDREWS & SPRINGER LLC, Wilmington, Delaware; Samuel L. Closic, Seth T. Ford, Robert B. Lackey, PRICKETT, JONES & ELLIOTT, P.A., Wilmington, Delaware; David Schwartz, John Vielandi, LABATON KELLER SUCHAROW LLP, New York, New York; Carl L. Stine, Adam J. Blander, WOLF POPPER LLP, New York, New York; Counsel for Co- Lead Plaintiffs; Donald J. Enright, Elizabeth K. Tripodi, LEVI & KORSINSKY, LLP, Washington, District of Columbia; Executive Committee for Co-Lead Plaintiffs.

Michael A. Pittenger, Matthew E. Fischer, Jacqueline A. Rogers, Nicholas D. Mozal, Charles P. Wood, POTTER ANDERSON & CORROON LLP, Wilmington, Delaware; Counsel for Defendants Edward S. Lampert, ESL Investments, Inc., ESL Partners, LP, RBS Partners, LP, Transform Holdco LLC, and Hometown Midco LLC.

LASTER, V.C. A controller engaged in a squeeze-out merger that eliminated the minority for

$3.21 per share. An investment fund sought appraisal. Other stockholders pursued a

plenary class action asserting claims for breach of fiduciary duty.

The fund became a general creditor of the surviving corporation by opting for

appraisal. The fund also became a general creditor of the surviving corporation’s post-

merger parent, because under the merger agreement, the fund could receive the

merger consideration from the post-merger parent if its appraisal claim terminated.

During the appraisal proceeding, the controller caused the surviving

corporation and its post-merger parent to file for bankruptcy. Both are insolvent;

their general creditors will receive nothing.

With those paths of recovery foreclosed, the fund opted to participate in the

plenary class action. After trial, the court held that the controller acted disloyally by

effectuating the squeeze-out merger and found that a fair price was $4.06 per share.

Focusing on the plenary class members who received the merger consideration, the

court awarded incremental compensatory damages equal to their out-of-pocket loss,

or $0.85 per share (the “Post-Trial Opinion”).1

The fund had not received the merger consideration, so the fund intervened to

establish its entitlement to the full fair-price damages award. The controller insisted

that the fund could only receive incremental compensatory damages, effectively

1 In re Sears Hometown & Outlet Stores, Inc. S’holder Litig., 309 A.3d 474 (Del.

Ch. 2024), modified on reargument, 2024 WL 3555781 (Del. Ch. July 2, 2024). offsetting the fund’s plenary recovery with merger consideration the fund never

received.

Relying on the Delaware Supreme Court’s decision in Technicolor2 and this

court’s decision in Mindbody,3 Emerging Communications4 and Dole Food,5 the court

held that the fund could recover the full measure of fair-price damages (the “Remedy

Opinion”).6 The court reasoned that the fund had the same entitlement to damages

as every other class member, but unlike the other class members, the fund had not

received the merger consideration. For the other class members, the merger

consideration functioned as an offset of $3.21 per share. The fund had nothing to

offset. The fund was therefore entitled to $4.06 per share.

The controller asked the court to certify an interlocutory appeal. This opinion

denies the application. First, the application was untimely. Second, the Remedy

Opinion did not resolve a substantial issue, nor does it meet any other criteria for

2 Cede & Co. v. Technicolor, Inc., 542 A.2d 1182 (Del. 1988).

3 In re Mindbody, Inc., S’holder Litig., 2023 WL 7704774 (Del. Ch. Nov. 15,

2023), aff’d in pertinent part, 2024 WL 4926910 (Del. Dec. 2, 2024).

4 In re Emerging Commc’ns, Inc. S’holders Litig., 2004 WL 1305745 (Del. Ch.

May 3, 2004).

5 In re Dole Food Co., Inc. S’holder Litig., 2015 WL 5052214 (Del. Ch. Aug. 27,

2015).

6 In re Sears Hometown & Outlet Stores, Inc. S’holder Litig., — A.3d —, 2024

WL 5403534 (Del. Ch. Feb. 13, 2025).

2 certification. Third, this case is on the verge of a final judgment that will support an

appeal as of right. An interlocutory appeal at this late date would risk burdening the

Delaware Supreme Court with multiple appeals. The final order doctrine calls for

limiting the controller to a single appeal.

I. FACTUAL BACKGROUND

Sears Hometown and Outlet Stores, Inc. (the “Company”) was a publicly traded

entity. Sears Holdings Corporation (“Holdings”) controlled it. Edward “Eddie” S.

Lampert controlled Holdings.

In 2019, the Company and Holdings agreed to a merger. Each Company share

was converted into the right to receive $3.21 from Transform Holdco LLC (“Parent”),

an entity that would emerge as the Company’s post-merger parent (the “Merger”).7

Parent was a wholly owned subsidiary of Holdings’ successor. Lampert controlled

every entity in the structure.

Stockholder plaintiffs challenged the Merger, contending Lampert and other

Company fiduciaries breached their duties by engaging in a squeeze-out transaction

at an unfair price (the “Plenary Action”). Cannon Square, LLC (the “Fund”) asserted

its right to an appraisal and sought a judicial determination of the fair value of its

shares (the “Appraisal Proceeding”). The court entered an order coordinating the

Plenary Action and the Appraisal Proceeding for purposes of discovery and trial.

7 This description oversimplifies a more complex transaction structure, but

suffices for purposes of this decision.

3 In 2022, the Company and Parent filed voluntary petitions for bankruptcy. By

seeking appraisal, the Fund became an unsecured general creditor of the Company.

The Fund was also an unsecured general creditor of Parent, because if its appraisal

claim terminated, then it could assert a contractual right to the merger consideration.

With the Company and Parent insolvent, both claims became worthless.

The Fund therefore chose to join the Plenary Action. That brought the size of

the class to 10,579,356 shares: the original 10,321,048 non-dissenting shares plus

another 258,308 dissenting shares held by the Fund.

In 2024, the court issued the Post-Trial Opinion finding that the Merger was

not entirely fair and that Lampert had breached his duty of loyalty. 8 Incorrectly

operating as if all class members received the merger consideration, the court

awarded compensatory damages “equal to the difference between what the minority

stockholders received and the fair value of the company.”9 After correcting an error,

that award amounted to $0.85 per share. With 10,579,356 shares in the class,

Lampert owed damages of $8,992,452.60, plus interest.

Because the Fund sought appraisal, the Fund had not received the merger

consideration.

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

In re Sears Hometown and Outlet Stores, Inc. Stockholder Litigation, (Del. Ct. App. 2025).

In re Sears Hometown and Outlet Stores, Inc. Stockholder Litigation (In re Sears Hometown and Outlet Stores, Inc. Stockholder Litigation) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Cede & Co. v. Technicolor, Inc.
542 A.2d 1182 (Supreme Court of Delaware, 1988)
Castaldo v. Pittsburgh-Des Moines Steel Co., Inc.
301 A.2d 87 (Supreme Court of Delaware, 1973)
Leal v. Meeks
115 A.3d 1173 (Supreme Court of Delaware, 2015)
Hazzard v. Harris
131 A.3d 324 (Supreme Court of Delaware, 2016)