The Delaware Court of Chancery, in Dr. Travis Martin v. Richard Bartlett, et al. and Harbor Diversified, Inc., C.A. No. 2018-0762-SG, memo. op. (Del. Ch. Feb. 5, 2020), found a stockholder was not entitled to an attorneys’ fees award for purported benefits incidentally obtained in litigation brought in pursuit of its own self-interested purpose of seeking a buy-out of his stock.

Francis Pileggi discusses the decision in – Chancery Denies Attorneys’ Fees for Successful Suit to Compel Annual Meeting.