Wisconsin

In re The Home Depot, Inc. Derivative Litigation in Wisconsin Law

How In re The Home Depot, Inc. Derivative Litigation applies in Wisconsin: state-specific rules, key cases, and bar exam notes for Corporate Law.

State Approach

Wisconsin's approach to derivative actions is contained within the Wisconsin Business Corporation Law, specifically focusing on the demand requirement and the business judgment rule. Similar to Delaware law but with Wisconsin-specific nuances, courts often emphasize the necessity of demonstrating that a demand on directors would have been futile.

State Rule
Under Wisconsin Statutes § 180.0744, shareholders must make a demand on directors before initiating a derivative action unless such demand is shown to be futile.
Significant State Cases

Owens v. State, 152 Wis. 2d 546 (1989)

The court held that demand futility must be particularly pleaded, making it difficult for shareholders to bypass the requirement.

Klein v. Lambert, 2008 WI App 169

Affirmed that shareholders must justify the futility of a demand, highlighting the business judgment rule.

Falkowski v. Tully, 2003 WI App 69

Examined the circumstances under which demand could be deemed futile, underscoring board discretion.

Comparison to Federal Law

Wisconsin's principles for derivative actions share similarities with federal law, particularly under Federal Rules of Civil Procedure Rule 23.1, which also requires a demand on directors but allows for greater latitude in proving futility. However, Wisconsin law is more specific in its statutory provisions regarding the procedural aspects of derivative claims.

Bar Exam Note

Understanding the demand requirement and the futility standard is crucial, especially as these concepts often appear in the Wisconsin bar exam regarding corporate law.

Practice Pointers
  • Always assess whether a demand was made to the board or demonstrate sufficient grounds for futility.
  • Be aware of the specific procedural requirements under Wisconsin Statutes § 180.0744 when drafting pleadings for derivative actions.
  • Expect to navigate the implications of the business judgment rule when challenging board decisions in derivative lawsuits.

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