Lieberman v. Wyoming.com LLC
Supreme Court of Wyoming
82 P.3d 274 (2004)
E. Michael Lieberman (plaintiff) was a member of Wyoming.com LLC (defendant) who served a notice of withdrawal demanding the return of his roughly $400,000 share of the company's current value. The remaining members accepted his withdrawal, elected to continue rather than dissolve the company, but refused to pay out his requested share; the parties' consolidated declaratory-judgment and dissolution actions led the district court to order liquidation of Lieberman's equity interest at his negative capital-account balance as of withdrawal, and Lieberman appealed.
Whether a court may liquidate a limited liability company member's equity interest in the company upon his dissociation, if he intended to withdraw his non-economic membership, but not his economic, or equity, interests in the company.