Bessemer Trust Co. v. Wilson, C.A. No. 6148-MA (Del. Ch. Sept. 28, 2011), read opinion here.
Whether this Delaware proceeding should be stayed in favor of a Florida action involving the effort to obtain information about the accessibility of trust funds.
Very Brief Overview
For purposes of this blog, this very brief overview will be limited to referencing the standard of review of a decision by a Master in Chancery, which under Court of Chancery Rule 144 is de novo as to findings of fact and conclusions of law. The focus in this case was whether certain persons were entitled to discovery of confidential financial information from the trustee concerning access to the corpus or interest of the trust. The Master in Chancery had stayed the proceedings in this Court in favor of a Florida action involving similar issues.
The issue on appeal from the report of the Master was whether this Court should continue the stay imposed by the Master, sua sponte, in favor of the Florida action. The Court of Chancery reasoned that the first-filed rule under the McWane doctrine does not support a stay because the parties in the Florida action and this action are not the same. In addition, the issues in this action and the Florida action are not the same. The main issue in this case was whether a beneficiary had an interest in the trust that was established for the benefit of his children. The main issue before the Florida Court was whether the beneficiary was liable for the death of a decedent and if so, the amount of damages.