In Merck Case, Supreme Court Tackles Shareholder Access to Corporate Documents
The dispute involves a Merck shareholder and his opposition to Merck's $8.4 billion acquisition of Cubist Pharmaceuticals.
December 19, 2018 at 04:37 PM
3 minute read
The New Jersey Supreme Court has agreed to determine how much inside information a shareholder is entitled to receive when he or she challenges business decisions made by a corporation's board of directors.
The court in a Dec. 17 order granting a certification petition agreed to hear a shareholder's appeal in Feuer v. Merck & Co. Oral arguments will likely be heard next year.
The court posted the question at issue: “Was plaintiff, a shareholder, entitled to inspect certain corporate documents, pursuant to statute, N.J.S.A. 14A:5-28(4) (books and records; right of inspection), or the common law?”
According to the Appellate Division's June 1 decision in the case, the dispute involves a Merck shareholder, F.A. Feuer, and his opposition to Kenilworth-based Merck's $8.4 billion acquisition of Cubist Pharmaceuticals, a Massachusetts-based manufacturer of drugs designed to combat infectious “superbugs.”
Feuer opposed the acquisition, contending that it was ill-advised and reckless because a number of Cubist's patents were being challenged. The acquisition went through anyway: It was announced in 2014 and completed in 2015.
Feuer continued to make objections to Merck's board of directors even after the acquisition, and the board appointed a three-member “working group” to look into Feuer's objections. Feuer has been seeking access to documents transmitted between the board, its counsel and its financial advisers to determine what steps it took to examine the patent challenges before going ahead with the Cubist purchase, the appeals court explained.
Both a Superior Court motion judge and the Appellate Division ruled that Feuer was not entitled to the documents he sought, specifically because of restrictions enacted by the Legislature in 1988 to the relevant statute, N.J.S.A. 14A:5-28, and because of common-law principles.
Feuer, the Appellate Division said, is entitled under the statute and common law to documents such as minutes and other administrative items.
“Reading the statute sensibly, it does not impose … a vaguely defined record-keeping obligation on corporations, nor does it grant courts the power to grant an equally vague scope of inspections to shareholders,” Appellate Division Judge Mitchel Ostrer wrote, joined by Judges Jack Sabatino and Mary Whipple.
State lawmakers purposefully chose to limit access to internal corporate information, Ostrer added.
“The New Jersey Legislature has expressly recognized the court's power to circumscribe the scope of inspection, stating that '[t]he court may, in its discretion, prescribe any limitation or conditions with reference to the inspection,'” Ostrer said, quoting a 2010 ruling in Cain v. Merck.
“Feuer is not entitled broad-ranging inspection … just because it would be useful,” Ostrer said.
Feuer's attorney, Lisa Rodriguez, said she was pleased the Supreme Court agreed to hear her client's appeal.
“We look forward to oral argument,” said Rodriguez, of the Cherry Hill office of Schnader Harrison Segal & Lewis.
Merck's attorney, J. Gordon Cooney of Morgan, Lewis & Bockius in Philadelphia, did not return a call seeking comment on the certification order.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllMeet the Judges: Senate Confirms 7 Superior Court Nominees in Final 2024 Session
3 minute readTrending Stories
- 1Decision of the Day: Administrative Court Finds Prevailing Wage Law Applies to Workers Who Cleaned NYC Subways During Pandemic
- 2Trailblazing Broward Judge Retires; Legacy Includes Bush v. Gore
- 3Federal Judge Named in Lawsuit Over Underage Drinking Party at His California Home
- 4'Almost an Arms Race': California Law Firms Scooped Up Lateral Talent by the Handful in 2024
- 5Pittsburgh Judge Rules Loan Company's Online Arbitration Agreement Unenforceable
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250