Fairstead Capital Management LLC v. William Blodgett
CourtSupreme Court of Delaware
Date FiledSeptember 10, 2026
Docket285, 2026
StatusPublished
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Full Opinion
IN THE SUPREME COURT OF THE STATE OF DELAWARE
FAIRSTEAD CAPITAL §
MANAGEMENT LLC and FCM § No. 285, 2026
AFFORDABLE LLC, §
§ Court Below–Court of Chancery
Plaintiffs Below, § of the State of Delaware
Appellants, §
§ C.A. No. 2022-0673
v. §
§
WILLIAM BLODGETT, §
§
Defendant Below, §
Appellee. §
Submitted: July 8, 2026
Decided: September 10, 2026
Before SEITZ, Chief Justice; TRAYNOR and GRIFFITHS, Justices.
ORDER
After consideration of the notice of appeal from an interlocutory order and its
exhibits, it appears to the Court that:
(1) In October 2013, William Blodgett and others started an affordable
housing business. The purpose of the business, “Fairstead,”1 was to source, develop,
own, and manage a portfolio of real estate investments. To that end, Blodgett entered
into an employment agreement with Fortitude Realty Management LLC,
1
The Fairstead fund complex comprised a variety of entities, including Fairstead Capital
Management LLC, FSC Realty Management LLC, FCM Affordable LLC, Fortitude Realty
Management LLC, FSC EF&F LLC, Fortitude Properties LLC, FSC-JD2 Member LLC, FCM-
JD2 LLC, and other special purpose vehicles. For simplicity, we use the term “Fairstead” to refer
to the business collectively unless the individual entity name is relevant.
(“Fortitude”), a Fairstead entity (the “Employment Agreement”). Under the
Employment Agreement, Blodgett would provide investment advisory services to
Fortitude and its affiliates. In compensation, Blodgett would receive, among other
things, 15% of the carried interest that Fairstead received in each business deal (the
“Interests”). To implement Blodgett’s right to the Interests, Fairstead gave Blodgett
member interests in two other Fairstead entities—Fairstead Capital Management
LLC; and FMC Affordable LLC (together, “Plaintiffs”).
(2) Fairstead terminated Blodgett’s employment in September 2021.
Blodgett’s official termination letter purported to terminate him for material
breaches of the Employment Agreement and also purported to cancel the Interests.
The letter did not refer to or allege any breach of the LLC agreements governing the
various Fairstead entities.
(3) In May 2022, Blodgett filed an arbitration demand under the
Employment Agreement, seeking determinations that he had not breached the
agreement and that Fairstead did not have the right to cancel the Interests. In August
2022, Plaintiffs filed suit in the Court of Chancery, alleging that Blodgett had
breached their LLC agreements and seeking declarations that they had properly
cancelled the Interests. Blodgett counterclaimed, arguing that Plaintiffs had
breached the LLC agreements by improperly cancelling the Interests. The Court of
Chancery held that disputes arising under the Employment Agreement must be
2
arbitrated and that any claims arising under Plaintiffs’ LLC agreements would
proceed in the Court of Chancery. The court stayed the litigation to allow arbitration
to proceed first.
(4) On April 2, 2025, the arbitrator issued an award. The arbitrator held,
among other things, that (i) Blodgett had breached the Employment Agreement, and
(ii) the Employment Agreement did not entitle Fairstead to cancel all the Interests,
only those in pending transactions. Thereafter, the parties cross-moved for summary
judgment in the Court of Chancery.
(5) On May 13, 2026, the Court of Chancery issued a decision resolving
the parties’ cross-motions for summary judgment.2 The court held that (i) Blodgett
was entitled to summary judgment on Plaintiffs’ claims because he “did not take any
action as a member that could support a breach of [the LLC agreements],”3 and (ii)
the LLC agreements did not permit cancellation of the Interests. The court has not
yet determined the amount of damages to which Blodgett is entitled. On June 10,
Plaintiffs moved for the entry of a partial final judgment under Court of Chancery
Rule 54(b) or, in the alternative, asked the court to certify an interlocutory appeal
under Supreme Court Rule 42 and issue a stay pending appeal. Blodgett opposed the
motion and application.
2
Fairstead Cap. Mgmt. LLC v. Blodgett, 2026 WL 1327565 (Del. Ch. May 13, 2026).
3
Id. at *19.
3
(6) On June 29, the Court of Chancery denied the motion and application.
The court recommended that this Court decline to accept an interlocutory appeal,
explaining, “This case is entering the damages phase and can be wrapped up
promptly.”
(7) We agree that interlocutory review is not warranted here. Applications
for interlocutory review are addressed to the sound discretion of the Court.4 In the
exercise of our discretion, this Court has concluded that the application for
interlocutory review does not meet the strict standards for certification under
Supreme Court Rule 42(b). As the Court of Chancery noted, there remains little to
be resolved before an appeal from a final order may be taken. Exceptional
circumstances that would merit interlocutory review of the Court of Chancery’s
decision do not exist in this case,5 and the potential benefits of interlocutory review
do not outweigh the inefficiency, disruption, and probable costs caused by an
interlocutory appeal.6
NOW, THEREFORE, IT IS ORDERED that the interlocutory appeal is
REFUSED.
BY THE COURT:
/s/ Collins J. Seitz, Jr.
Chief Justice
4
Del. Supr. Ct. R. 42(d)(v).
5
Del. Supr. Ct. R. 42(b)(ii).
6
Del. Supr. Ct. R. 42(b)(iii).
4