By Stacy Nettleton and Christie Di Guglielmo ( September 11, 2017, 12:16 PM EDT) -- Three and a half years ago, the Delaware Supreme Court provided a path to business judgment rule review of "squeeze-out" mergers in which a controlling stockholder buys out the company's minority stockholders. Specifically, the court in Kahn v. M&F Worldwide Corp., 88 A.3d 635 (Del. 2014) held that the deferential business judgment rule standard of review — rather than the more exacting entire fairness test — applies to a merger in which a controlling stockholder takes a company private if the merger is conditioned, from the outset, upon both (1) negotiation and approval by a committee of independent directors that is fully empowered to select its own advisers, to exert real bargaining power and to say no definitively, and that fulfills its duty of care, and (2) the uncoerced, informed approval of a majority of the minority stockholders. Last month, the Delaware Court of Chancery extended the MFW holding, concluding that the business judgment rule also applies to a merger between a company and a third party in which a controlling stockholder is alleged to have received special benefits or treatment, provided the MFW conditions are met. In re Martha Stewart Living Omnimedia Inc. Stockholder Litigation, Cons. C.A. No. 11202-VCS (Del. Ch. Aug. 18, 2017)....