Mercier v. Inter-Tel and the Reformulation of the Blasius Standard

July 3, 2008

Andrew Carriker

On August 14, 2007, the Delaware Court of Chancery decided Mercier v. Inter-Tel, Inc.1 One of the more interesting conclusions the court delivered was that the Blasius standard should be reformulated “as a genuine standard of review that is useful for the determination of cases, rather than as an after-the-fact label placed on a result.” “Such a reformulation,” the court said, “would be consistent with prior decisions recognizing the substantial overlap between and redundancy of the Blasius and Unocal standards, and would have the added benefit of creating a less prolix list of standards of review.”

Mercier v. Inter-Tel and the Reformulation of the Blasius Standard