Supreme Court of Delaware
Eagle Force Holdings v. Campbell
July 8, 2020
Summary
The court affirmed the Court of Chancery’s conclusion that Campbell did not objectively manifest assent to be bound by either transaction document and therefore did not consent to personal jurisdiction through those documents or the April 2014 letter agreement. It also affirmed contempt sanctions for violations of the status quo order while jurisdiction was being adjudicated, but reversed the contempt ruling and disgorgement relating to payments made during the interim appeal period because the order had been dissolved and was not stayed or renewed. The opinion also held that the absence of a sworn affidavit did not invalidate the contempt proceedings where Campbell had notice of the order and the facts supporting contempt.