Kasten v. Doral Dental USA, LLC
Supreme Court of Wisconsin
733 N.W.2d 300 (2007)
Marie Kasten (plaintiff) was a member of Doral Dental USA, LLC (defendant) who suspected management was acting against her interests, and requested to inspect company records including emails and document drafts. Doral refused to produce all of the requested materials, and Kasten sued to compel inspection. The circuit court held the emails and drafts were not subject to inspection under either the Wisconsin Limited Liability Company Law (WLLCL) or Doral's own operating agreement. Kasten appealed, and the court of appeals certified the scope-of-inspection question to the state supreme court.
Whether an LLC member's contractual right to inspect any record or company document upon reasonable request includes the right to inspect emails and document drafts.