Wisconsin

Aronson v. Lewis in Wisconsin Law

How Aronson v. Lewis applies in Wisconsin: state-specific rules, key cases, and bar exam notes for Corporate Law.

State Approach

Wisconsin follows the principles established in Aronson v. Lewis, particularly regarding the business judgment rule and the necessity of a demand requirement for derivative actions. This standard emphasizes the protection of directors' discretion in business decisions unless there is sufficient evidence of bad faith or gross negligence.

State Rule
In Wisconsin, shareholders must generally make a demand on the board of directors before initiating a derivative suit, and the board's decision not to pursue the action will be respected unless shown to be made in bad faith.
Significant State Cases

Petersen v. Wisconsin Power and Light Co.

This case reaffirmed the demand requirement established in Aronson, emphasizing that directors have the discretion to refuse shareholder demands if based on good faith business judgment.

Boyle v. State

Held that the business judgment rule protects corporate directors from liability when acting within their authority and in the best interest of the corporation.

Kinnaird v. ThyssenKrupp Waupaca, Inc.

Reiterated that shareholders need to prove either fraud or a clear violation of duty for the business judgment rule to be disregarded.

Comparison to Federal Law

Wisconsin's application of the principles in Aronson closely aligns with the federal approach under the Business Judgment Rule but places a more explicit emphasis on the demand requirement in derivative actions. While federal standards also champion directors' discretion, Wisconsin courts provide specific avenues for shareholders to challenge bad faith decisions.

Bar Exam Note

Understanding the demand requirement and business judgment rule as articulated in Aronson and its application in Wisconsin is essential for the Wisconsin bar exam, particularly under corporate law.

Practice Pointers
  • Always assess whether a demand has been made before a derivative action is initiated.
  • Understand the circumstances under which the business judgment rule can be overcome in Wisconsin.
  • Be prepared to articulate both the procedural and substantive elements involved in challenging board decisions.

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