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Lovenheim v. Iroquois Brands, Ltd.

United States District Court for the District of Columbia
618 F. Supp. 554 (1985)

Written by Sean Carroll, JD

Facts

Peter Lovenheim (plaintiff) was a shareholder in Iroquois Brands, Ltd. (Iroquois) (defendant). Iroquois was preparing to send proxy materials to its shareholders containing information about a shareholder meeting. Lovenheim sought to include in the proxy materials a proposed resolution that he planned to offer at the meeting. The resolution pertained to the allegedly inhumane procedures used in France to force-feed geese for production of pâté de foie gras, which was a type of pâté imported by Iroquois. Iroquois refused to include information on Lovenheim’s resolution in the proxy materials. Iroquois defended its refusal based on the Securities and Exchange Commission rule that a corporation may omit a proposal from its proxy statement “if the proposal relates to operations which account for less than 5 percent of [Iroquois’s] total assets at the end of its most recent fiscal year . . . and is not otherwise significantly related to [Iroquois’s] business.” Pâté accounted for well less than 5 percent of Iroquois’s business. However, Lovenheim maintained that his proposal could not be excluded because of the second part of the rule in that it could not be said that the proposal was not otherwise significantly related to Iroquois’s business. Lovenheim argued that the proposal had ethical or social significance.

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