Barrett, et al. v. Toroyan, download file , is an Appellate New York State Court decision applying Delaware law. My thanks to David J. Hoffman of New York City for referring this case to me for a short summary on my blog. The New York court, applying Delaware law, found that directors of corporate general partners can be personally liable for self-dealing transactions, even if there is a clause in the Limited Partnership Agreement allowing members to pursue competitive business interests. The court relied on several Delaware cases including the following: Continental Insurance Co. v. Rutledge, 750 A.2d 1219 (Del. 2000); Kahn v. Icahn, 1998 Del. Ch. LEXIS 223 (Del. Ch. 1998); Gotham Partners, LP v. Hallwood Realty Partners LP, 817 A.2d 160 (Del. 2002).