Klauder v. Echo/rt Holdings, LLC

Summary

The Supreme Court of Delaware affirmed dismissal of the Trustee's fraudulent-transfer claims because the debtor's wholly owned subsidiary, not the debtor, transferred the assets, and the Trustee did not establish an exception to the separate-corporate-entity rule. The court also held that the Trustee forfeited an argument based on the subsidiary's dissolution because he did not fairly present it below. Finally, the court held that the bankruptcy automatic stay did not apply to claims against nondebtor entities or make the Court of Chancery's judgment void.