Adelsperger v. Elkside Development LLC

Summary

The Oregon Supreme Court reversed the trial court’s summary‑judgment grant on the elder‑abuse claim, affirmed the grant on the breach‑of‑contract claim, and left the intentional‑interference claim affirmed by an equally divided court, remanding the case for further proceedings. The Court held that ORS 63.165 does not shield individual LLC members from direct liability for statutory elder‑abuse violations, but does bar breach‑of‑contract claims where the members lack privity. The decision rests on statutory interpretation and the established privity requirement.