Chancery Pulse

Delaware Court of Chancery — Trusts & Estates Digest
March 9 – April 9, 2026 • 7 opinions reviewed • 0 T&E relevant • 1 of potential interest

This Period at a Glance

No T&E-Specific Opinions This Period

The Court of Chancery published 7 opinions between March 9 and April 9, 2026, all in corporate/commercial matters. This is not unusual — T&E opinions tend to cluster, and a 30-day dry spell happens several times per year.

Worth watching: Delaware's trust code amendments (effective January 2026) have not yet generated published Chancery opinions interpreting the new provisions. Early test cases may emerge in the next quarter.

Corporate/Commercial Opinions

NICbyte LLC v. StarTop Investments, LLC

Case No.: C.A. No. 2023-0637-NAC Date: April 8, 2026 Judge: Cook, V.C. Type: Post-Trial Memorandum Opinion
Corporate — Not T&E Relevant

Summary

Post-trial opinion addressing fraud, spoliation of evidence, and enforcement of security interests over property owned by LLCs. The defendant's agent (a "rogue manager") created fraudulent loan documentation. The Court found intentional evidence destruction, imposed an adverse inference sanction, and granted injunctive relief against enforcement of the fraudulently obtained security interests.

Of Note

The Court's spoliation analysis and burden-shifting framework could be relevant in trust/estate litigation where document destruction is alleged — particularly in will contests or trustee breach claims involving missing records.

LG Land, LLC v. Dream Finders Holdings, LLC

Case No.: C.A. No. 2025-0459-MTZ Date: April 7, 2026 Judge: Zurn, V.C. Type: Letter Decision
Corporate — Not T&E Relevant

Summary

Dispute over an asset purchase agreement with post-closing price adjustments. The Court distinguished between "arbitration" (which has statutory Chancery jurisdiction) and "expert determination" (which does not), dismissing the confirmation petition for lack of subject matter jurisdiction.

Diem-II, LLC v. Maisonette Inc.

Case No.: C.A. No. 2025-0338-BWD Date: April 6, 2026 Judge: David, V.C. Type: Memorandum Opinion
Corporate — Not T&E Relevant Fiduciary Duty (Corporate)

Summary

Investors in a Delaware e-commerce startup sued the company and its directors/officers for fraud, breach of fiduciary duty, and securities violations. Plaintiffs alleged they received inaccurate financial information in connection with preferred stock and convertible note purchases, and that a director had undisclosed pending securities litigation. The Court resolved motions to dismiss.

Of Note

The fiduciary duty and disclosure obligation analysis, while in a corporate context, tracks similar principles applicable to trustee disclosure duties. The treatment of what constitutes "material" information may be useful by analogy.

Fresh Express Vegetable, LLC v. Latitude 36 Foods, LLC

Case No.: 2025-1050-SEM (MTZ) Date: April 2, 2026 Judge: Zurn, V.C. Type: Order Regarding Exceptions
Corporate — Not T&E Relevant Advancement/Indemnification

Summary

An LLC member sought advancement of legal expenses for defense against claims, relying on the operating agreement's advancement and indemnification provisions. The dispute turned on interpretation of the agreement's "good faith" requirement and scope of covered proceedings.

Of Note

Operating agreement advancement provisions closely parallel trust instrument indemnification clauses. The Court's interpretation of "good faith" triggers and scope limitations is directly transferable to drafting trustee indemnification provisions.

In Re Reinz Wisconsin Gasket, LLC

Case No.: 2022-0859-MTZ Date: April 2, 2026 Judge: Zurn, V.C. Type: Memorandum Opinion
Corporate — Not T&E Relevant Entity Dissolution

Summary

A products liability claimant sought to nullify the certificate of cancellation of a dissolved LLC, alleging the dissolution improperly avoided liability by failing to reserve assets for claimants. The Court examined whether insurance policies and litigable claims constituted "assets" at the time of dissolution under the Delaware LLC Act.

Of Note

Relevant for estate plans using LLCs as holding vehicles. The analysis of what constitutes "assets" for dissolution purposes — and the obligation to reserve for known and unknown claimants — parallels estate administration creditor-claim obligations.

Sorrento Therapeutics Inc. v. Anthony Mack

Case No.: C.A. No. 2021-0210-PAF Date: April 2, 2026 Judge: Fioravanti, V.C. Type: Order (Attorneys' Fees)
Corporate — Not T&E Relevant

Summary

Following a remedy opinion finding breach of restrictive covenants, trade secret misappropriation, and breach of fiduciary duty by a former employee, this order addresses the fee application. Employment/corporate opportunity dispute.

Sujit Gaikwad v. Jason A. Gilbert

Case No.: C.A. No. 2025-1396-DG Date: April 2, 2026 Judge: Gibbs, M. Type: Order (Default Judgment)
Corporate — Not T&E Relevant

Summary

Procedural order confirming a final arbitration award of $1,645,180.49 against respondents who failed to appear. Commercial dispute involving petroleum/development businesses.

Opinion PDF Links

NICbyte v. StarTop Investments (Apr. 8, 2026 — Cook, V.C.)
LG Land v. Dream Finders Holdings (Apr. 7, 2026 — Zurn, V.C.)
Diem-II v. Maisonette Inc. (Apr. 6, 2026 — David, V.C.)
Fresh Express Vegetable v. Latitude 36 Foods (Apr. 2, 2026 — Zurn, V.C.)
In Re Reinz Wisconsin Gasket, LLC (Apr. 2, 2026 — Zurn, V.C.)
Sorrento Therapeutics v. Mack (Apr. 2, 2026 — Fioravanti, V.C.)
Gaikwad v. Gilbert (Apr. 2, 2026 — Gibbs, M.)