WLR FOODS, INC. V. TYSON FOODS, INC. 65 F.3d 1172 (4th Cir. 1995) CASE BRIEF

WLR FOODS, INC. V. TYSON FOODS, INC.
65 F.3d 1172 (4th Cir. 1995)
NATURE OF THE CASE: Tyson (D) appealed a denial of relief in WLR's (P) declaratory relief action over the constitutionality of antitakeover statutes in the Va. Code.
FACTS: D, a nationwide poultry producer, sought to acquire P, a chicken and turkey producer. P's board adopted various defensive measures to protect P against the takeover. D eventually presented a tender offer directly to the stockholders of P, but withdrew the offer several months later, claiming that, due to actions taken by the P Board, D's offering price was no longer reflective of the value of P's stock. Tyson appealed several rulings of the district court, which found that the defensive tactics adopted by the P were a valid legal means by which to respond to the threatened takeover. In particular D thought that Section 690 of the Virginia Business Judgment Statute allowed a court to inquire into the processes employed by directors in making decisions with respect to the takeover, and not into the substance of the decisions. The court had denied D discovery of substantive materials and content used by P in response to the takeover. D appealed.

ISSUE:


RULE OF LAW:


HOLDING AND DECISION:


LEGAL ANALYSIS:





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