Tzolis v. Wolff

Managers of Pennington Property Co., LLC (PPC) allegedly colluded to lease and later sell PPC's Manhattan apartment building for below fair market value, and minority members owning a collective 25% stake (plaintiffs) sued both individually and derivatively on PPC's behalf seeking to void the sale and terminate the lease; the trial court dismissed both theories, reasoning the individual claim belonged to PPC itself and that New York's LLC statute didn't authorize derivative suits, but the appellate court reversed on the derivative-suit question, and the defendants appealed.