On March 6, 2017, the Massachusetts Supreme Judicial Court issued a decision that illustrates the limited remedies available to shareholders challenging the merger of a Massachusetts corporation. In Local No. 129 Benefit Fund v. Joseph M. Tucci et al., 476 Mass. 553 (Mass. 2017), shareholders of a publicly traded Massachusetts corporation claimed that the directors breached their fiduciary duties by failure to take actions to maximize the value of the corporation's stock and by agreeing to unreasonable deal protection provisions that discouraged the possibility of better bids.