#5 · 2026-08-11 · Case
Meinhard v. Salmon
The New York Court of Appeals held that the managing joint venturer had to give his co-venturer a chance to participate in the lease opportunity stemming from their enterprise. The opinion is a classic statement of fiduciary loyalty, not a universal rule that every later deal belongs to a former venture.
Rule to remember
Meinhard v. Salmon held that a manager of an ongoing joint venture breached a fiduciary duty by taking for himself, without disclosure, a closely related opportunity obtained through the venture.
Key elements and checks
- An ongoing joint venture with one venturer managing its hotel lease.
- A redevelopment opportunity reaching the manager because of that role.
- Secret appropriation of the opportunity without giving the co-venturer a fair chance.
In the source’s words
“A trustee is held to something stricter than the morals of the market place.”
Meinhard v. Salmon, 249 N.Y. 458 (1928)
The opinion applies New York fiduciary law to its facts; the boundaries of venture opportunities and remedies are jurisdiction- and agreement-sensitive.