Buckley v. Carlock – Appellate court affirms “blue-sky” method for valuing car dealerships

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Abstract: The Tennessee Court of Appeals recently affirmed a lower court’s application of the so-called “blue-sky” method to determine fair value in a shareholder oppression case. This article summarizes the details of the case and explains that courts are allowed to tweak generally accepted valuation methodology to achieve an equitable outcome under the fair value standard. A sidebar addresses the issue of recovery for attorneys’ fees by the prevailing party. Buckley v. Carlock, No. M2019-02294-COA-R3-CV (Tenn. App. Feb. 28, 2022).