News & Analysis as of

Covenant of Good Faith and Fair Dealing Good Faith

King & Spalding

S.D.N.Y. Reiterates that the Implied Covenant of Good Faith and Fair Dealing May Not Create Obligations Inconsistent with Parties’...

King & Spalding on

On March 25, 2025, the U.S. District Court for the Southern District of New York denied a motion to dismiss a lender’s claims for declaratory judgment and other relief under an intercreditor agreement (“ICA”), rejecting the...more

Miller Canfield

Michigan Supreme Court Confirms: No Independent Cause of Action for Breach of Implied Covenant of Good Faith

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Sometimes an expected result is still newsworthy. On March 27, 2025, in Kircher v Boyne USA, Inc., the Michigan Supreme Court held that there is no independent cause of action for breach of the implied covenant of good faith...more

Zelle  LLP

Federal Court Correctly Concludes that a Simple Disagreement Between Experts Does Not Support a Claim for the Breach of the Duty...

Zelle LLP on

U.S. District Court Xavier Rodriguez of the United States District Court for the Western District of Texas recently issued a decision granting summary judgment for an insurance carrier in a first-party case involving alleged...more

Davis Wright Tremaine LLP

CBCA Addresses How To Avoid Release Language in an Executed Contract Modification

Contractors frequently execute modifications for extra work without considering the impact the boilerplate broad release language in the modification may have on future claims. Government agencies often seek dismissal of a...more

Patton Sullivan Brodehl LLP

Another Case Addressing Managerial Discretion and the Implied Covenant of Good Faith and Fair Dealing

LLC managers often enjoy wide latitude and unrestricted “discretion” under the LLC’s operating agreement. At the same time, all contracts — including LLC operating agreements — are subject to the implied covenant of good...more

ArentFox Schiff

Claims Narrowed in Jack Nicklaus Non-Competition Case Over IP Sale

ArentFox Schiff on

On April 12, 2023, a Manhattan judge in the lawsuit regarding the sale of golf legend Jack Nicklaus’s intellectual property portfolio narrowed the claims against Nicklaus. In 2007, Nicklaus sold his intellectual property...more

Rivkin Radler LLP

New York Insurance Coverage Law Update - March 28 2023

Rivkin Radler LLP on

Southern District Finds That Exclusion In HO3 Form Precludes Coverage Even Though Form Inadvertently Omitted From Copy Of Policy Sent To Insured- Scottsdale Insurance Company issued a homeowner’s policy to 232 Dune Road...more

Goodwin

“Good Faith” in Shareholders’ Agreements: What Does it Mean?

Goodwin on

Shareholder agreements often include an obligation that the shareholders must act with “good faith” in their dealings with one another and with the company. However, what does that actually mean? In this insight, we consider...more

Patton Sullivan Brodehl LLP

LLC Managers or Members With “Sole Discretion” Must Still Act in Good Faith

LLC managers (or members vested with decision-making authority) are sometimes lulled into a false sense of security by “sole discretion” provisions in their LLC’s operating agreement.  That can be a costly mistake....more

Carlton Fields

Eleventh Circuit Takes Life Insurance Reinstatement Claims at Face Value for CAFA Amount-In-Controversy Purposes

Carlton Fields on

The Eleventh Circuit recently examined the application of the $5 million amount-in-controversy requirement under the Class Action Fairness Act (CAFA) to disputes over life insurance premiums and policies. It concluded that...more

White & Case LLP

Contractual duties of good faith in "relational contracts"

White & Case LLP on

In a long running group litigation between a number of Sub-Post Masters and Post Office Limited, Mr Justice Fraser, sitting in the English High Court, has given detailed consideration of the issue of relational contracts in...more

Morrison & Foerster LLP - Government...

Who Bears the Risks of War?

On the eve of the Vicksburg campaign in October 1862, Abraham Lincoln instructed Ulysses S. Grant, “Follow law, and forms of law, as far as convenient.” In a war zone, Lincoln seemed to recognize, there may be some...more

Morrison & Foerster LLP - Government...

O Ye of Little Faith: Breaching the Duty of Good Faith and Fair Dealing While Complying with the Express Terms of a Government...

In contracts – and especially in government contracts, where one is expected to “turn square corners” – we often analyze breach of contract in light of the jots and tittles of a contract’s express terms. And, in bringing a...more

Pullman & Comley, LLC

Point of Interest: Sixth Circuit Complicates Sureties’ Duty Of “Good Faith”

Pullman & Comley, LLC on

A hefty body of law declares that “suretyship is not insurance,” and so that sureties are not subject to claims for the tort of insurance bad faith. E.g., Upper Pottsgrove Township v. Internat’l Fidelity Ins. Co., 976...more

Orrick - Finance 20/20

Court Grants in Part and Denies in Part DB Structured Products’ Motion to Dismiss Trustee Repurchase Action

Orrick - Finance 20/20 on

On August 28, Justice Marcy S. Friedman of the Supreme Court of the State of New York granted in part and denied in part DB Structured Products, Inc.’s motion to dismiss repurchase claims brought by HSBC, as Trustee for the...more

Pillsbury Winthrop Shaw Pittman LLP

Who Says Life’s Not Fair: Good Faith and Fair Dealing Prevails in Metcalf Case.

In a ruling highly anticipated among government contractors, the United States Court of Appeals for the Federal Circuit held on February 11, 2014, in Metcalf Construction Company, Inc. v. United States, No. 2013-5041 (Fed....more

Cadwalader, Wickersham & Taft LLP

Delaware Court Allows Claims For Breach Of Implied Good Faith Covenant In Earn-Out Case

A recent Delaware Chancery Court opinion in American Capital Acquisition Partners, LLC, et. al. v. LPL Holdings, Inc., et.al. held that a seller’s claim that its buyer diverted opportunities from the acquired business to a...more

Sheppard Mullin Richter & Hampton LLP

Delaware Supreme Court Holds That a Minority Stockholder Has No Common Law Right to a Conflict-Free Board Decision Regarding the...

In Blaustein v. Lord Baltimore Capital Corp., No. 272, 2013, 2014 Del. LEXIS 30 (Del. Jan. 21, 2014), the Delaware Supreme Court held that a closely-held corporation’s directors owe no fiduciary duty to decide, free from...more

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