Reese v. Newman
District of Columbia Court of Appeals
131 A.3d 880 (2016)
Relevant factsFree
Allison Reese (defendant) and Nicole Newman (plaintiff) co-owned ANR Construction Management, LLC. After management disagreements, Newman sued to dissolve the LLC, while Reese wanted to keep running the company and counterclaimed to have Newman dissociated instead. A jury found grounds existed for both dissociation and dissolution, and the trial court ordered dissolution. Reese appealed, arguing that once grounds for dissociation exist, the statute's use of "shall" requires the court to order dissociation rather than dissolution.
IssueFree
Whether, when grounds exist for both dissolution of an LLC and dissociation of a member, a court has discretion to choose between the two remedies.