Spence v. Sloan
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The Supreme Court affirmed the judgment of the district court finding that the Spence Group lacked standing to bring the underlying derivative action, holding that the district court did not abuse its discretion in ruling that the Spence Group failed to show it did not have an adequate remedy at law.
The dispute in this case was between two factions of the former Board of Directors of the Wyoming Trial Lawyers College - the Spence Group and the Sloan Group. The Spence Group brought a derivative action against the Sloan Group and the College alleging that some or all of the Sloan Group directors should be removed from the Board and seeking a declaration that the Spence Group members were the only duly acting members. The district court dismissed the case for lack of standing. The Supreme Court affirmed, holding that the district court properly granted the Sloan Group summary judgment on its claim that the Spence Group lacked standing to bring its derivative action.
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