Omnicare, Inc. v. NCS Healthcare, Inc.

Citation

818 A.2d 914 (Del. 2003)

Facts

Stub — to be completed.

Issue

Stub — to be completed.

Holding

Stub — to be completed.

Rule

A merger agreement that is preclusive and coercive — locking up shareholder votes to make rejection impossible — is invalid even if supported by a majority of shareholders; deal protection measures may not completely foreclose the board’s fiduciary duties.

Significance

Invalidated a deal structure that gave the acquirer an irrevocable majority lock-up; established limits on deal protection measures under Revlon.

Courses