RBC Capital Markets, LLC, et al. v. Education Loan Trust IV, et al.
Annotate this CasePlaintiff-appellant RBC Capital Markets, LLC (RBC) appealed a Superior Court judgment dismissing its claims against the defendant-appellees U.S. Education Loan Trust IV, LLC and Education Loan Trust IV. RBC sued the Defendants in the Court of Chancery in 2011, alleging that Defendants had been paying excessive fees from the Trust. The court dismissed the Chancery action as barred by the Trust Indenture’s "no-action" clause. Then in 2012, RBC filed this case, claiming that the Defendants had unlawfully failed to pay interest owed to RBC under the Issuer notes that RBC held. The Superior Court dismissed, finding: (1) the complaint failed to state a claim upon which relief can be granted; and (2) that the earlier Court of Chancery judgment of dismissal precluded RBC’s claim as res judicata. Upon review, the Supreme Court concluded the Superior Court erred in dismissing the case. The Court held that RBC’s complaint satisfied Delaware’s "reasonable conceivability" pleading standard, that the claim was not barred by the Trust Indenture’s no-action clause, and that on the current record it could not be determined as a matter of law that RBC’s Superior Court claim was precluded as res judicata.
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