Bainbridge on Corporations

Bainbridge on Corporations

Are Plaintiff Attorneys' Fee Awards in the Delaware Chancery Court Excessive? Part II

Hanrahan's Response to Dor and Grundfest

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Stephen Bainbridge
Nov 25, 2025
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In the first post of this series, I discussed a new-ish article by Joseph Grundfest and Gal Dor of the Stanford Law School on plaintiff fee awards in the Delaware Chancery court. In it, I noted that their study was controversial and promised that future posts would discuss some of the comments their paper elicited.

Bainbridge on Corporations
Are Plaintiff Attorneys' Fee Awards in the Delaware Chancery Court Excessive? Part I
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3 days ago · Stephen Bainbridge

Dor, Gal and Grundfest, Joseph A., Lodestar Multipliers in Delaware and Federal Attorney Fee Awards (August 04, 2025). Stanford Public Law Working Paper, Available at SSRN: https://ssrn.com/abstract=5379166

In this post, I take up a response by Delaware trial lawyer Michael Hanrahan, along with Dor & Grundfest’s response thereto.

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At the outset, I should make clear that I don’t have a personal stake in this debate. I do not know either Mr. Hanrahan or Ms. Dor. I’ve met Professor Grundfest at a couple of professional events and occasionally exchanged emails about various professional matters. As for a professional/policy stake in the debate, my view that “derivative litigation mainly serves as a means of transferring wealth from investors to lawyers” is hardly a closely guarded secret. But that’s a debate for another day. At the moment, we’re concerned with figuring out the facts not jousting over policy preferences.

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