Fourth Circuit -- Beach First National Bancshares v. Michael Anderson

Bankruptcy trustee of parent corporation has standing for breach of fiduciary duty suit against directors of subsidiary bank taken over by the FDIC only with respect to a real estate transaction that affected the rights of the parent corporation.

Beach First National Bancshares v. Michael Anderson

Third Circuit -- In Re: Lemington Home

Given red flags, old-age home's directors not shielded under business judgement rule.

Whether board members benefited personally is a matter for trial - determines whether the adverse interest exception to in pari delicto applies.

In Re: Lemington Home