Jarvis v. Elliott, C.A. No. 4753-CC (Del. Ch. March 5, 2010), read opinion here. This 18-page decision is as fun as it gets when it comes to reading judicial decisions.
Although the amounts involved in this case are more fitting for a small claims court, and the primary legal issues are replevin and conversion, the main reason I include this decision on this blog–which seeks to cover all the key decisions on corporate and commercial law from Delaware’s Chancery Court and Supreme Court, is due to the memorable manner in which the opinion is written. It includes a combination of serious adjudication mixed with multiple references to famous race car drivers, movies about race cars and other indications that the author of this opinion is quite familiar with the industry from which the parties in this case arrive at the Court. This decision also highlights the reality that not all business disputes in Chancery are billion dollar disputes among Fortune 100 companies. The Court in this case awarded a total of $1,260.67–though the opinion is just as thoughtfully written as if it were one of the many major disputes the Court handles.
The opening line to the ruling deserves to be quoted: "Success on the track does not guarantee success off the track. With regret that a winning team fell apart, I must now sort through the wreckage of a failed relationship…."
The Court explained that replevin was typically not within its jurisdiction but that it retained it in this case under the "whole case or controversy" doctrine based on initial partnership claims. Before defining the elements of a replevin action, the Court began its analysis thusly: "My analysis will be swifter than Richard Petty’s race-clinching pit stop at the 1981 Daytona 500. The chassis of this case is a replevin action".
The Court also referred in footnotes to famous movies featuring racing. See footnotes 50, 51 and 52. Demonstrating a firm grip on the details of the racing industry, the Court acknowledged towards the end of its decision the importance of backup engines and backup cars by the following reference: "Just ask Jimmie Johnson, who recently won one of the 2010 Daytona 500 qualifiers in a backup car."