A federal district court judge introduced an opinion on the fiduciary obligation of corporate directors by stating that "the doctrine of the fiduciary relation is one of the most confused and entangled subjects in corporation law." In Zahn v. Transamerica Corporation the fiduciary duties of corporate directors were discussed extensively by the Third Circuit Court of Appeals. The court not only failed to terminate the confusion and clear the entanglement but may well have added to it by using the fiduciary concept in a new field.
Leroy H. Redfern S.Ed.,
CORPORATIONS-REDEEMABLE STOCK-FIDUCIARY DUTY OF DIRECTORS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol46/iss8/4