Crane

INTRODUCTION

Brian Crane initiated an action for involuntary dissolution of R. R. Crane Investment Corporation, Inc. (R. R. Crane), a family-owned investment business that he shared with his brother Kevin Crane. To avoid corporate dissolution, Kevin and R. R. Crane invoked the statutory appraisal and buyout provisions of the Corporations Code. 1 In December of 2020, after a prolonged appraisal process, the trial court confirmed the fair value of Brian’s shares at over $6.1 million, valued as of November 13, 2017, the date Brian filed for dissolution. On appeal Brian contends the trial court erred by failing to award him prejudgment interest on the valuation of his shares. He argues he was entitled to interest at a rate of 10 percent per annum from the date he first sought dissolution until the eventual purchase of his shares more than three years later. We disagree that prejudgment interest must be added to the appraised value of Brian’s shares, and we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. History of R. R. Crane and Brian’s Complaint Seeking Involuntary Dissolution R. R. Crane is a family-owned corporation formed in 1960 by Brian’s and Kevin’s parents. The corporation…