The Iowa Court of Appeals addressed whether shareholders in a closely-held corporation, in this case a professional corporation of physicians, owed fiduciary duties to one another and whether the claims for breach of those duties could be brought directly rather than derivatively. On both points the Iowa Court of Appeals said no. McGinnis v. Iowa Clinic, P.C., 2009 WL 2424643 (Iowa App., August 6, 2009).
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