I didn't care much for Civil procedure in law school and, obviously, I don't blog about it much. But since some readers may, I pass along a link to our friend Francis Pileggi's article for Directorship on Hazout v. Tsang, which broadened the scope of personal jurisdiction in Delaware courts over officers and directors of Delaware corporations. Here's what seems to be the money quote, but do go read the whole thing:
Delaware courts have historically interpreted Section 3114 to only impose personal jurisdiction on directors and officers of a Delaware corporation when claims against them were made for breach of fiduciary duty or other related violations of the Delaware General Corporation Law. Thus, this decision is notable because it expands the interpretation of the statute to allow directors and officers of Delaware corporations to be subject to the jurisdiction of Delaware courts when they are merely a necessary party (e.g., a person whose interests are impacted by the outcome of a lawsuit) or a proper party (someone who merely has a legal interest in a lawsuit), even if there are no claims for breach of fiduciary duty.
