McLeod v. Stevens

BUTZNER, Circuit Judge:

In this diversity action governed by South Carolina law, the district court held that the appellants, six shareholders and officers of the Sandy Island Corporation, violated the statutory and equitable rights of a minority shareholder, Michele McLeod. We find no error in the court’s determination of liability and in the equitable relief it ordered, but we vacate the award of compensatory and punitive damages.

Five of the six appellants, in concert with two others who sold their shares before this suit arose, formed the corporation to hold and develop a tract of land…