Conversion Claims Cannot Reach Uncertificated LLC Membership Interests Under Texas Law

In Carrington v. Corsi, the Business Court of Texas granted Rule 91a dismissal of plaintiffs' conversion claim arising from an allegedly wrongful transfer and dilution of their LLC membership interests, holding that Texas conversion law does not recognize uncertificated LLC interests as property subject to conversion. The decision applies the First Court of Appeals' reasoning in Bell v. Bay Area RV Parks and rejects plaintiffs' arguments where no physical certificates were alleged to have been issued or converted.