Mitchell Partners, L.P. v. AMFI Corp.

CourtCourt of Chancery of Delaware
DecidedJuly 28, 2025
DocketC.A. No. 2020-0985-KSJM
StatusPublished

This text of Mitchell Partners, L.P. v. AMFI Corp. (Mitchell Partners, L.P. v. AMFI Corp.) 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
Mitchell Partners, L.P. v. AMFI Corp., (Del. Ct. App. 2025).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE KATHALEEN ST. JUDE MCCORMICK LEONARD L. WILLIAMS JUSTICE CENTER CHANCELLOR 500 N. KING STREET, SUITE 11400 WILMINGTON, DELAWARE 19801-3734

July 28, 2025

R. Bruce McNew Lisa M. Zwally Cooch and Taylor, P.A. Bryan T. Reed The Brandywine Building Greenberg Traurig, LLP 1000 N. West Street, Suite 1500 222 Delaware Avenue, Suite 1600 P.O. Box 1680 Wilmington, Delaware 19801 Wilmington, Delaware 19899

Re: Mitchell Partners, L.P. v. AMFI Corp. et al., C.A. No. 2020-0985-KSJM

Dear Counsel:

This decision resolves the motions of Plaintiff Mitchell Partners, L.P.

(“Plaintiff”) for summary judgment on Counts I and III of the Second Amended

Verified Class Action Complaint (the “Second Amended Complaint”).1

I. BACKGROUND

I assume the reader’s familiarity with this action and refer to my earlier

decisions for additional background.2

1 See C.A. No. 2020-0985-KSJM, Dockets (“Dkts.”) 108 (“Second Am. Compl.”), 143

(Mot. for Summ. J. on Count I of the Second Am. Compl.), 169 (Mot. for Summ. J. as to Count III of the Second Am. Compl.). 2 See Mitchell P’rs, L.P. v. AMFI Corp., 2024 WL 3289389 (Del. Ch. July 3, 2024)

(resolving motion to dismiss Counts III through V of the Second Amended Complaint), reargument denied, 2024 WL 3650692 (Del. Ch. Aug. 5, 2024); Mitchell P’rs, L.P. v. AMFI Corp., 2024 WL 3290843 (Del. Ch. July 3, 2024) (resolving motion for exceptions to the special magistrate report). C.A. No. 2020-0985-KSJM July 28, 2025 Page 2 of 14

The parties dispute whether AMFI Corporation (“AMFI” or the “Company”)

validly issued 20,000 shares of Class B common stock in 1982 (the “Class B Shares”).

This dispute has manifested in claims concerning AMFI’s stock ledger.

Plaintiff holds AMFI Class A common stock.3 In late 2020, Plaintiff received

AMFI’s 2019 financial statement.4 It stated that AMFI had 20,000 Class B Shares

outstanding.5 Plaintiff alleges that this came as a surprise, because Plaintiff was

unaware of the Class B Shares before that time.6 All of the Class B Shares are

currently held by AMFI subsidiaries and affiliates, T.H.B. Corp., Little Sabine, Inc.,

Dunes Motel, Inc., and Holi Corp. (the “Subsidiary Defendants”).7 Plaintiff sent a

demand to inspect AMFI’s stock ledger under Section 220 of the Delaware General

Corporation Law (“DGCL”) to learn more about the Class B Shares.8 In response,

AMFI offered to produce a series of “stockholder cards” for inspection.9

3 Dkt. 135 (“Answer to Second Am. Compl.”) ¶ 8.

4 See Dkt. 99, Ex. 1 (AMFI Corporation and Subsidiaries Consolidated Financial

Statement, December 31, 2019). 5 Id. at 1.

6 Second Am. Compl. ¶ 4.

7 Answer to Second Am. Compl. ¶¶ 11–14.

8 Id. ¶ 6.

9 See Second Am. Compl. ¶ 3 (citing Ex. B (Letter from Defendants’ counsel responding to Plaintiff’s Section 220 demand)); Second Am. Compl., Ex. B at 2 (stating that AMFI “does not maintain a current stock list in the regular course of business” but noting that “[t]he Company does maintain stockholder cards, and those will be made available for inspection”); Answer to Second Am. Compl. ¶ 3 (stating that Ex. B “speaks for itself”). C.A. No. 2020-0985-KSJM July 28, 2025 Page 3 of 14

Victoria Corporaal, AMFI’s Transfer Agent and Rule 30(b)(6) representative

regarding the Company’s stock ledger, explained that AMFI maintains five types of

records regarding AMFI stock ownership. Those are: “active” stock cards; “inactive”

stock cards; “transfer packages”; a current list of the names and addresses of all

stockholders of record in an electronic document; and a “control card.”10

The active and inactive cards are hardcopy cardstock cards.11 A set is kept for

each individual stockholder itemizing the sales and purchases of stock in that

stockholder’s name.12 A set might contain multiple cards.13 Only the initial card

contains the stockholder’s contact information and address.14 Active cards reflect

current stockholders. Inactive cards reflect former stockholders and have a current

balance of zero shares.15 None of the stock cards reflect AMFI’s Class B Shares,16 and

until this litigation, Corporaal, who had worked on and off at the Company since the

1970’s,17 was unaware that AMFI had Class B Shares.18

10 Dkt. 83 (“Corporaal Dep. Tr.”) at 29:14–30:22, 34:4–18, 37:24–39:24, 44:4–6.

11 Id. at 47:3–12.

12 Dkt. 10 ¶¶ 2–3.

13 Corporaal Dep. Tr. at 83:5–84:5.

14 See Dkt. 143 (“Pl.’s Count I Opening Br.”), Ex. A; Corporaal Dep. Tr. at 83:5–84:8.

15 Corporaal Dep. Tr. at 34:7–11, 66:10–17.

16 Id. at 103:25–104:2 (“Q. Do you have any kind of a ledger card for a class B share?

A. I do not.”). 17 Id. at 11:14–12:1.

18 Id. at 117:22–118:3 (“Q. Did you ever get instruction one way or another to exclude

non-voting stocks [from the stock cards]? A. I didn’t know we had non-voting stocks. C.A. No. 2020-0985-KSJM July 28, 2025 Page 4 of 14

The transfer packages are communications regarding stock transfers. 19 They

include any cancelled stock certificates.20 They are grouped by year.21 It is

Corporaal’s practice to destroy the oldest records once she runs out of storage room

for them.22

The current list and names of stockholders is an electronic document that

Corporaal updates every time shares are retired or transferred.23

What Corporaal refers to as the “control card” is a running total of the number

of outstanding shares of AMFI stock.24 She updates it when shares are cancelled or

retired. She refers to the card as the ledger.25

When Plaintiff initiated this litigation in November 2020, the original

complaint contained two causes of action.26 In Count I, Plaintiff alleged that AMFI

failed to maintain an accurate stock ledger in violation of Sections 219 and 220 of the

DGCL.27 In Count II, Mitchell Partners alleged that the individual defendants—Jack

Q. So as far as you know, throughout your entire tenure as the transfer person at AMFI, AMFI has only had one class of voting stock? A. That is correct.”). 19 Id. at 29:19–30:17.

20 Id.

21 Id. at 31:6–12.

22 Id. at 29:1–32:10.

23 Id. at 37:24–38:2.

24 Id. at 39:11–40:22.

25 Id.

26 See Dkt. 1.

27 Id. ¶¶ 22–27. C.A. No. 2020-0985-KSJM July 28, 2025 Page 5 of 14

B. Yancy, Carolyn Pugh, Barbara Woodbury, Marilyn Hess, and Carol Harrison (the

“Director Defendants” and together with AMFI and the Subsidiary Defendants,

“Defendants”)—breached their fiduciary duties by failing to cause AMFI to create and

maintain an adequate stock ledger.28

Plaintiff twice amended its complaint.29 The operative complaint is the Second

Amended Complaint, which contains five Counts:

• Count I alleges that the Company failed to keep and maintain a valid stock ledger.30

• Count II alleges the Director Defendants breached their fiduciary duties by failing to cause AMFI to keep and maintain a valid stock ledger.31

• Count III seeks three alternative forms of declaratory relief as to AMFI and the Subsidiary Defendants: (i) that no Class B Shares are issued or outstanding; or (ii) that if the Class B Shares were issued, the issuance was defective and they are void; or (iii) if the Class B Shares were validly issued, the transfers of the shares to the Subsidiary Defendants constituted waste.32

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Bluebook (online)
Mitchell Partners, L.P. v. AMFI Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-partners-lp-v-amfi-corp-delch-2025.