Blasband v. Rales
United States Court of Appeals for the Third Circuit
971 F.2d 1034 (1992)
- Written by Mary Phelan D'Isa, JD
Facts
Blasband (plaintiff) owned shares in Easco Hand Tools, Inc. (Easco). Easco was merged into another corporation, Danaher, and became Danaher’s wholly owned subsidiary. As a result of the merger, Blasband’s stock in Easco was converted into Danaher stock. Blasband alleged that during the time Blasband held Easco stock, the Rales (defendants), two directors of Easco, violated their fiduciary duties to Easco. When Blasband brought his shareholder derivative suit against the Rales, his Easco stock had been converted to Danaher stock. The Rales argued that Blasband lacked standing to bring his shareholder derivative suit because he no longer owned Easco stock at the time he filed his action, which was required under applicable law that followed the contemporaneous ownership rule for shareholder derivative suits. The district court agreed and dismissed the suit. Blasband appealed.
Rule of Law
Issue
Holding and Reasoning (Greenberg, J.)
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