Court Says Expulsion Price Determination in Louisiana Buyout Dispute Is Triable Issue

BVLaw
Court Case Digests
June 6, 2019
7361 Employment Agencies
561311 Employment Placement Agencies
judicial dissolution
trade secret, business valuation, discount for lack of control (DLOC), expert testimony, fair value, buyout, discount for lack of marketability (DLOM), expert valuation, fair market value (FMV), limited liability company, minority discount, operating agreement

Complete Logistical Services, LLC v. Rulh
2019 U.S. Dist. LEXIS 95701
US
Federal Court
Federal
United States District Court (E.D. Louisiana)
Jason MacMorran (plaintiff); Athen Sweet (defendant)
Fallon

Summary

In buyout dispute resulting from expulsion of LLC member, court finds state law does not preclude use of discounts in valuing withdrawing LLC member’s interest; company’s operating agreement is ambiguous on how to value expelled member’s interest, court says, leaving issue for jury to decide.

See Also

Complete Logistical Services, LLC v. Rulh

In buyout dispute resulting from expulsion of LLC member, court finds state law does not preclude use of discounts in valuing withdrawing LLC member’s interest; company’s operating agreement is ambiguous on how to value expelled member’s interest, court says, leaving issue for jury to decide.