On November 17, 2023, the Delaware Court of Chancery in Teamsters Local 443 Health Services & Insurance Plan v. Chou clarified that limited personal relationships, without more, generally will be insufficient to render directors not independent. In granting the special litigation committee’s motion to dismiss, the court rejected plaintiffs’ argument that the sole member of that committee lacked independence based on his connections to one of the company’s directors through their membership at the same golf club.