Kevin McLaren v. Smash Franchise Partners, LLC

CourtSupreme Court of Delaware
DecidedJune 12, 2024
Docket376, 2023
StatusPublished

This text of Kevin McLaren v. Smash Franchise Partners, LLC (Kevin McLaren v. Smash Franchise Partners, LLC) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin McLaren v. Smash Franchise Partners, LLC, (Del. 2024).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

KEVIN MCLAREN, § § No. 376, 2023 Defendant Below, Appellant, § § Court Below: Court of Chancery v. § of the State of Delaware § SMASH FRANCHISE PARTNERS, § C.A. No. 2020-0302 LLC, § § Plaintiff Below, Appellee. §

Submitted: May 8, 2024 Decided: June 12, 2024

Before SEITZ, Chief Justice; TRAYNOR and GRIFFITHS, Justices.

ORDER

After consideration of the parties’ briefs and the record on appeal, and

following oral argument, it appears to the Court that:

(1) The appellant, Kevin McLaren, appeals from the Court of Chancery’s

September 8, 2023 Order and Final Judgment (the “Judgment”), in which the court,

after issuing a post-trial opinion in July 2023, ordered the parties to bear their own

fees and costs. McLaren contends that the Court of Chancery abused its discretion

by failing to address his request for attorney’s fees under the Delaware Uniform

Trade Secrets Act (“DUTSA”) in the Judgment. McLaren also appeals from the

Court of Chancery’s June 12, 2020 discovery ruling (the “Discovery Ruling”)

denying his June 2020 motion for a protective order and awarding fees to appellee Smash Franchise Partners, LLC (“Smash”). We find no merit to his arguments and

affirm.

(3) On April 20, 2020, Smash1 filed suit against McLaren—as well as

against his business associate Todd Perri, Dumpster Devil LLC, and Kanda

Holdings, Inc. 2—asserting eight causes of action including a claim for

misappropriation of trade secrets in violation of DUTSA against all defendants. In

October 2022, one month before trial, Smash informed the court and defendants that

it would not try most of its claims, including its DUTSA claim. McLaren was not

included as a defendant on the remaining claims.

(4) In defendants’ pretrial briefing, they collectively petitioned for

attorney’s fees under DUTSA.3 In the parties’ pretrial stipulation, McLaren sought

attorney’s fees on three grounds, one of those being the attorney’s fees provision of

DUTSA.4 The court entered judgment in favor of McLaren at trial. 5 In defendants’

1 The other plaintiff, Smash My Trash, LLC, is not a party to this appeal and was not a party to Smash’s June 2021 second amended complaint in the Chancery litigation. 2 None of these defendants are parties to this appeal. Herein, we refer to all the defendants below, including McLaren, collectively as “defendants.” The defendants were represented by the same counsel. 3 App. to Opening Br. at A614 (cleaned up) (“Defendants should be awarded their attorney’s fees and costs in defending [Smash’s] claims under the Uniform Trade Secrets Act.”). 4 Id. at A728 (“Defendants respectfully request that the Court [of Chancery] issue an Order . . . . [a]warding Defendant Kevin McLaren his costs, including reasonable attorney[’s] fees pursuant to the bad faith exception to the American Rule regarding attorney[’s] fees and to 6 Del. C. § 2004 [attorney’s fees provision of DUTSA], 6 Del. C. § 2533(b) [attorney’s fees provision of the Delaware Uniform Deceptive Trade Practices Act].”). 5 Smash Franchise Partners, LLC v. Kanda Holdings, Inc., 2023 WL 4560984, at *15 (Del. Ch. July 14, 2023).

2 post-trial briefing, they again collectively asked for attorney’s fees under DUTSA. 6

As to McLaren, they argued that although he “was not named in a count that provides

for statutory fee shifting, he is nonetheless entitled to an award of fees under the

[Court of Chancery’s] general equitable powers.”7 At post-trial oral argument,

counsel did not make a request for attorney’s fees on behalf of McLaren, though he

did ask for McLaren to be dismissed from the case. 8 On April 23, 2023, the court

dismissed McLaren from the case.9

(5) On July 14, 2023, the Court of Chancery issued a memorandum opinion

and order (the “July Opinion”). 10 The court ordered each party to bear its own costs

and awarded no attorney’s fees under DUTSA (or under any other theory).11 On

September 8, 2023, the court entered the Judgment, which also ordered each party

to bear its own fees and costs. 12

(6) On appeal, McLaren claims that the Court of Chancery erred by failing

to address McLaren’s request for attorney’s fees in the Judgment. He also contends

6 App. to Opening Br. at A894. 7 Id. at A898–99. 8 See id. at A914–15. 9 Ch. Dkt. No. 329 at 3 (“Smash has no remaining claims against McLaren; therefore, McLaren is dismissed as a defendant in this action.”). 10 Smash Franchise Partners, LLC v. Kanda Holdings, Inc., 2023 WL 4560984 (Del. Ch. July 14, 2023). 11 Id. at *30. 12 Smash Franchise Partners, LLC v. Kanda Holdings, Inc., 2023 WL 5899953, at *1 (Del. Ch. Sep. 8, 2023).

3 that the Court of Chancery erred in denying defendants’ June 2020 motion for

protective order and awarding attorney’s fees to Smash. We review an award of

attorney’s fees for abuse of discretion.13 We review pretrial discovery rulings for

abuse of discretion. 14

(7) McLaren first contends that the Court of Chancery abused its discretion

by failing to address his request for attorney’s fees under DUTSA. His argument is

without merit as the July Opinion and the Judgment explicitly and implicitly address

his request for attorney’s fees. At the outset of the July Opinion, the trial court stated

that “[n]either side in this case deserves any relief. . . . Through the financial and

personal consequences of this extensively litigated case, each side has received its

just desserts. Each side will bear its own costs.”15 The Judgment, which identified

McLaren as one of the defendants, also states that “[e]ach party will bear its own

fees and costs.”16

(8) The Court of Chancery’s decisions also implicitly address whether

McLaren was entitled to attorney’s fees. The July Opinion found that, although the

defendants were the prevailing party on Smash’s DUTSA claim because Smash

dropped the claim on the eve of trial, Perri (one of the remaining defendants) did not

13 Sugarland Indus., Inc. v. Thomas, 420 A.2d 142, 149 (Del. 1980). 14 Coleman v. PricewaterhouseCoopers, LLC, 902 A.2d 1102, 1106 (Del. 2006) (citing ABB Flakt, Inc. v. Nat’s Union Fire Ins. Co., 731 A.2d 811, 815 (Del. 1999)). 15 Smash Franchise Partners, LLC, 2023 WL 4560984, at *2. 16 Smash Franchise Partners, LLC, 2023 WL 5899953, at *1.

4 “show that the claim fits under one of the enumerated circumstances warranting an

award of attorney[’s] fees” under 6 Del. C. § 2004. 17 McLaren does not

convincingly explain how the Court of Chancery’s finding that Smash did not pursue

an objectively specious DUTSA claim would apply any differently to his fee

application. The Judgment also states that Dumpster Devil, another remaining

defendant, was not entitled to attorney’s fees under DUTSA. 18

(9) Moreover, in the July Opinion, the Court of Chancery instructed the

parties to submit a joint letter to the court if there were any outstanding issues to be

addressed to bring the matter to a conclusion.19 The parties did not do so. At oral

argument before this Court, McLaren’s counsel conceded that he did not inform the

trial court that McLaren’s fee issue remained outstanding. 20 In sum, the Court of

Chancery sufficiently and correctly ruled that McLaren was not entitled to attorney’s

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

Related

Coleman v. PRICEWATERHOUSECOOPERS, LLC
902 A.2d 1102 (Supreme Court of Delaware, 2006)
SmithKline Beecham Pharmaceuticals Co. v. Merck & Co., Inc.
766 A.2d 442 (Supreme Court of Delaware, 2000)
Sugarland Industries, Inc. v. Thomas
420 A.2d 142 (Supreme Court of Delaware, 1980)
ABB Flakt, Inc. v. National Union Fire Insurance Co. of Pittsburgh
731 A.2d 811 (Supreme Court of Delaware, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
Kevin McLaren v. Smash Franchise Partners, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kevin-mclaren-v-smash-franchise-partners-llc-del-2024.