New York Court of Appeals Roundup: Court of Appeals Tackles International Business Dispute in 'Eccles v. Shamrock Capital Advisers'
07.16.24
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In their column in the New York Law Journal, Litigation Partners Bill Russell and Linton Mann III explore Eccles, et al. v. Shamrock Capital Advisers, et al. The Court of Appeals’ unanimous decision clarified the choice-of-law principles governing alleged breaches of fiduciary duties in international business disputes. The Court held that, with rare exception, breach of fiduciary duty claims are governed by the internal affairs doctrine which provides for a presumption that the substantive law of the place of incorporation applies to disputes involving the internal affairs of a corporation. The decision underscores the importance of understanding the law of the jurisdiction in which a corporation is incorporated since some jurisdictions provide that a director’s fiduciary duties extend beyond the corporation to individual shareholders.
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