Board of Trustees of Leland Stanford Junior University v. Zhang
- Jon Tigar
- 4:19-cv-02904
- U.S. District Court · Northern District of California
- 12
In Board of Trustees v. Zhang, Judge Tigar denied part and granted part of the pleadings motion, preserving one counterclaim and ending three others.
Zhang’s public-disclosure-of-private-facts counterclaim remains after the motion was denied as to it; her three fiduciary-duty-related counterclaims were subject to the granted motion.
What happened
Board of Trustees of Leland Stanford Junior University v. Zhang concerns claims over diaries, letters, photographs, and other materials connected to Li Rui. Zhang alleged that Stanford and others publicly disclosed private facts by displaying and providing the materials to researchers, and that fiduciary-duty claims survived Li Rui’s death.
The court denied the motion as to Zhang’s public-disclosure-of-private-facts counterclaim, holding that allegations that multiple people viewed the materials over about six weeks were enough at the pleading stage. The court granted the motion as to Zhang’s fiduciary-duty, aiding-and-abetting, and conspiracy counterclaims, concluding under Chinese law that those claims were not inheritable.
Judge Tigar’s order therefore granted in part and denied in part the motion for judgment on the pleadings. The public-disclosure counterclaim remains, while the seventh through ninth counterclaims are subject to the granted motion.
The detailed version
- Board of Trustees of Leland Stanford Junior University v. Zhang · No. 4:19-cv-02904
- Jon Tigar
- Sept. 28, 2022
Background
Stanford brought a quiet-title action concerning physical materials associated with Li Rui, including diaries, letters, photographs, work notes, and manuscripts. Stanford alleged that Li Rui gave the materials to his daughter, Li Nanyang, to transfer ownership to Stanford. Zhang, Li Rui’s second wife, disputed Stanford’s ownership and asserted counterclaims against Stanford and Li Nanyang.
The pending motion sought judgment on the pleadings under Federal Rule of Civil Procedure 12(c) on Zhang’s second, seventh, eighth, and ninth counterclaims. The challenged claims were public disclosure of private facts; breach of fiduciary duty; aiding and abetting breach of fiduciary duty; and conspiracy to commit breach of fiduciary duty.
Public Disclosure of Private Facts
The court applied California law for purposes of the motion. A public-disclosure-of-private-facts claim requires public disclosure of a private fact that would offend a reasonable person and is not a matter of legitimate public concern. The motion focused on whether Zhang had alleged the required public disclosure.
Counter-Defendants argued that making documents available to researchers at an archive was not sufficiently public. The court rejected that argument at the pleading stage. It explained that the relevant question is not a fixed numerical threshold but whether the communication was public rather than private and was likely to become public knowledge.
Zhang alleged that Stanford displayed the materials at a panel discussion and that the materials were later made available to researchers. She also alleged that multiple people viewed them during approximately six weeks after the reading room reopened. The court held that these allegations constituted a public disclosure for purposes of the motion. It therefore denied the motion as to the second counterclaim.
Fiduciary-Duty Counterclaims
Counter-Defendants argued that Chinese law made the fiduciary-duty claims personal to Li Rui and that the claims did not survive his death. The parties agreed that Chinese law governed these claims. The court considered an expert declaration concerning the Chinese Law of Succession and related provisions of Chinese law.
The court concluded that, under Article 3 of the Law of Succession, rights arising from the decedent’s personal relationships were not part of inheritable estate property. The court further concluded that Zhang had not identified a specific Chinese-law provision providing standing to bring these fiduciary-duty claims. The Chinese proceeding awarding Zhang ownership of the materials did not change the result because it concerned ownership, not the fiduciary-duty claims.
The court therefore granted the motion as to the seventh, eighth, and ninth counterclaims: breach of fiduciary duty, aiding and abetting breach of fiduciary duty, and conspiracy to commit breach of fiduciary duty.
Disposition
The order states that Counter-Defendants’ motion for judgment on the pleadings was denied as to the second counterclaim and granted as to the seventh through ninth counterclaims. The opinion does not state that either ruling was with or without prejudice.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.