Supreme Court of Delaware

North American Fire Ultimate Holdings, LP v. Alan Doorly

February 3, 2026

Summary

The Court reversed dismissal of the plaintiff’s contract claims and remanded for further proceedings. It held that consideration is evaluated when a contract is formed, not when the agreement is later enforced, and that equity units subject to vesting and forfeiture requirements can constitute non-illusory consideration at formation. The Court reviewed the legal issues de novo.