Vill. Press, Inc. v. Stephen Edward Co., 416 A.2d 1373 (N.H. 1980). · Go Syfert
Vill. Press, Inc. v. Stephen Edward Co., 416 A.2d 1373 (N.H. 1980). Cases Citing This Book View Copy Cite
73 citation events (36 in the last 25 years) across 8 distinct courts.
Strongest positive: Delta MB LLC v. 271 South Broadway, LLC (nhd, 2024-08-15)
Treatment trajectory · 1981 → 2026 · click a year to view as-of
1981 2003 2026
Top citers, strongest first. 23 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Delta MB LLC v. 271 South Broadway, LLC
D.N.H. · 2024 · signal: see also · quote attribution · 1 verbatim quote · confidence high
the fact that one person controls two corporations is not sufficient to make the two corporations and the controlling stockholder the same person under the law.
discussed Cited as authority (verbatim quote) Delta MB LLC v. 271 South Broadway, LLC, et al.
D.N.H. · 2024 · signal: see also · quote attribution · 1 verbatim quote · confidence high
the fact that one person controls two corporations is not sufficient to make the two corporations and the controlling stockholder the same person under the law.
examined Cited as authority (verbatim quote) In Re Martin (2×) also: Cited as authority (rule)
Bankr. D.N.H. · 2008 · quote attribution · 1 verbatim quote · confidence high
in order to avail itself of the benefits of the alter ego doctrine, thereby piercing the corporate veil, the plaintiff must establish that the corporate entity was used to promote an injustice or fraud.
discussed Cited as authority (verbatim quote) U.S. v. Kattar
D.N.H. · 1999 · quote attribution · 1 verbatim quote · confidence high
plaintiff must establish that the corporate entity was used to promote an injustice or fraud
examined Cited as authority (verbatim quote) Doyle v. Hoyle Ins. (2×) also: Cited as authority (quoted)
D.N.H. · 1995 · quote attribution · 2 verbatim quotes · confidence high
the close nature of the corporation is not by itself enough to justify piercing the corporate veil
cited Cited as authority (rule) Watts v. Liberty Mutual Personal Insurance Company
D. Mass. · 2025 · confidence medium
Press, Inc. v. Stephen Edward Co., 120 N.H. 469, 471 (1980) (citing Waff Bros., Inc. v. Bank of N. C., N. A., 289 N.C. 198 , 210–11 (1976)).
cited Cited as authority (rule) AMA Systems, LLC v. 3B Tech, Inc.
D. Maryland · 2023 · confidence medium
Press, Inc. v. Stephen Edward Co., 120 N.H. 469, 471 (1980).
cited Cited as authority (rule) Homes Development Corp. v. Edmund & Wheeler, Inc.
D.N.H. · 2022 · confidence medium
Press, Inc. v. Stephen Edward Co., 120 N.H. 469, 471 (1980) (citations omitted).
cited Cited as authority (rule) Spencer v Eversource
D.N.H. · 2017 · confidence medium
Press, Inc. v. Stephen Edward Co., 120 N.H. 469, 471 (1980)).
discussed Cited as authority (rule) GE Mobile v Red Desert Reclamation
D.N.H. · 2014 · confidence medium
Press, Inc. v. Stephen Edward Co., Inc., 120 N.H. 469, 472 (1980); whether the corporate assets have been intermingled, Zimmerman v. Puccio, 613 F.3d 60, 74 (1st Cir. 2010) (applying Massachusetts law); and whether corporate formalities have been observed, see Mbahaba, 163 N.H. at 569 .
examined Cited as authority (rule) Antaeus Enterprises et al. v. Davidson (3×) also: Cited "see"
D.N.H. · 2011 · confidence medium
Stephen Edward Co., 120 N.H. 469, 471 (1980) (stating that plaintiffs bear the burden of proof on veil-piercing claims under New Hampshire l a w ) .
discussed Cited as authority (rule) Norwood Group, Inc. v. Phillips
N.H. · 2003 · confidence medium
In such a case, we will disregard the fiction that the corporation is independent of its stockholders and treat the stockholders as the corporation’s “alter egos.” See Village Press v. Stephen Edward Co., 120 N.H. 469,471-72 (1980).
discussed Cited as authority (rule) Sheppard v. River Valley, et al.
D.N.H. · 2002 · confidence medium
It may well be that the limited partnership and its successive general partners constitute a "single employer" for Title VII purposes, but, the limited partnership's decision to seek bankruptcy protection, even coupled with the GP entities' Hampshire Supreme Court has "held that a court may pierce the corporate veil if a shareholder suppresses the fact of incorporation . . ." Drudinq v. Allen, 122 N.H. 823, 827 (1982) (citing Village Press v. Stephen Edward Co., 120 N.H. 469, 471-72 (1980); Ashland Lumber Co. v. Haves, 119 N.H. 440, 441 (1979); Peter R.
discussed Cited as authority (rule) McCarthy v. Azure
1st Cir. · 1994 · confidence medium
App. Ct. 1992) (barring a subsidiary from piercing its own corporate veil in order to reach its parent because "the equitable remedy lies with third parties"), aff'd, _____ 1994 WL 28672 (Feb. 3, 1994); Village Press, Inc. v. Stephen ____________________ _______ Edward Comp., Inc., 416 A.2d 1373, 1375 (N.H. 1980) (holding ___________________ that, to employ the alter ego doctrine, "the plaintiff must establish that the corporate entity was used to promote an injustice or fraud").
discussed Cited as authority (rule) McCarthy v. Azure
1st Cir. · 1994 · confidence medium
Co., 238 Ill.App.3d 292 , 179 Ill.Dec. 459, 464 , 606 N.E.2d 291, 296 (1992) (barring a subsidiary from piercing its own corporate veil in order to reach its parent because “the equitable remedy lies with third parties”), aff'd, 158 Ill.2d 166 , 198 Ill.Dec. 404 , 632 N.E.2d 1015 (1994); Village Press, Inc. v. Stephen Edward Comp., Inc., 120 N.H. 469 , 416 A.2d 1373, 1375 (1980) (holding that, to employ the alter ego doctrine, “the plaintiff must establish that the corporate entity was used to promote an injustice or fraud”).
cited Cited as authority (rule) Jack C. Keir, Inc. v. Robinson & Keir Partnership
Vt. · 1989 · confidence medium
Village Press, Inc. v. Stephen Edward Co., 120 N.H. 469, 471-72 , 416 A.2d 1373, 1375 (1980); Alterio v. Biltmore Construction Corp., 119 R.I. 307, 315 , 377 A.2d 237, 241 (1977); Roberts v. W.H.
cited Cited as authority (rule) Harman v. Bertholet (In Re Cycle-Rama, Inc.)
Bankr. D.N.H. · 1988 · confidence medium
Village Press v. Stephen Edward Co., 120 N.H. 469, 471-72 , 416 A.2d 1373, 1375 (1980); Ashland Lumber Co. v. Hayes, 119 N.H. 440, 441 , 402 A.2d 201, 202 (1979); Peter R.
cited Cited as authority (rule) Druding v. Allen
N.H. · 1982 · confidence medium
Village Press v. Stephen Edward Co., 120 N.H. 469, 471-72 , 416 A.2d 1373, 1375 (1980); Ashland Lumber Co. v. Hayes, 119 N.H. 440, 441 , 402 A.2d 201, 202 (1979); Peter R.
examined Cited "see" ANTAEUS ENTERPRISES, INC. v. Davidson (4×) also: Cited "see, e.g."
D.N.H. · 2011 · signal: see · confidence high
See Village Press, 120 N.H. at 471 , 416 A.2d 1373 .
discussed Cited "see" Hangar One, Inc. v. Davis Associates, Inc. (2×)
N.H. · 1981 · signal: see · confidence high
See Village Press v. Stephen Edward Co., 120 N.H. 469 , 416 A.2d 1373 (1980); Ashland Lumber Co. v. Hayes, 119 N.H. 440 , 402 A.2d 201 (1979).
discussed Cited "see" K-Ross Building Supply Center, Inc. v. Winnipesauke Chalets, Inc. (2×)
N.H. · 1981 · signal: see · confidence high
See Village Press v. Stephen Edward Co., 120 N.H. 469, 470-71 , 416 A.2d 1373, 1374 (1980).
discussed Cited "see, e.g." United States v. Kattar (2×)
D.N.H. · 1999 · signal: see also · confidence low
Comer Family Equity Trust v. United States, 732 F.Supp. 755, 759 (E.D.Mi.1990); Loving Saviour Church, 556 F.Supp. at 691-92; see also, Village Press, Inc. v. Stephen Edward Co., 120 N.H. 469 , 416 A.2d 1373 (1980).
Retrieving the full opinion text from the archive…
The Village Press, Inc.
v.
Stephen Edward Company, Inc. & A.
79-261.
Supreme Court of New Hampshire.
Jun 25, 1980.
416 A.2d 1373
1980 N.H. LEXIS 325
Frederic T. Greenhalge, of Concord, by brief and orally, for the plaintiff., Gerald R. Prunier, of Nashua, by brief and orally, for the defendant, Stephen E. Blum.
Brock.
Cited by 29 opinions  |  Published
1 passage pin-cited by 1 case
Pinpoint authority: bottom 68%
Citer courts: D. New Hampshire (1)
BROCK, J.

The sole issue for our consideration in this case is whether sufficient evidence was presented at trial to hold Stephen E. Blum personally liable for the debts of two corporations which he controlled. We hold that the evidence was insufficient and set aside the verdict entered against Blum, individually.

In November 1976, the plaintiff negotiated with Stephen Blum, as agent for the Stephen Edward Co., Inc., to prepare mail order catalogues for Pridecraft, Inc. Stephen Blum controlled both the Stephen Edward Company and Pridecraft. The parties exchanged correspondence and entered into an agreement whereby the plaintiff would print the Pridecraft catalogues and bill Stephen Edward Company, Inc. Plaintiff delivered the catalogues, but due to a dispute over their quality, neither corporation tendered payment. Plaintiff then brought this action, and after trial the Master (Robert A. Carignan, Esq.) recommended a verdict for the plaintiff against both corporations and Stephen Blum, individually. The Superior Court (Johnson, J.) approved the master’s recommendation and reserved and transferred defendant Blum’s exceptions.

No evidence was presented at trial that indicated that Blum suppressed the fact that his businesses were incorporated. In fact, the exhibits show that the defendant mailed all of his correspondence on letterheads of the Stephen Edward Co., Inc. and signed them “Stephen Blum, President.” Plaintiff, in turn, sent its correspondence to Stephen Blum at the Stephen Edward Company. Moreover, no evidence was offered that Blum ever made[*471] any agreement to hold himself personally responsible for his corporations’ debts. See Ashland Lumber Co. v. Hayes, 119 N.H. 440, 402 A.2d 201 (1979).

Plaintiff argues that Blum personally controlled the corporations, making them, in effect, his alter egos. Plaintiff concludes therefrom that Blum is personally liable for their debts. Under the alter ego doctrine, however, piercing the corporate veil is not permitted solely because a corporation is a one-man operation. Farmers Feed & Supply Co. v. United States, 267 F. Supp. 72, 78 (N.D. Iowa 1967); IZE Nantan Bagowa, Ltd. v. Scalia, 118 Ariz. 439, 577 P.2d 725 (Ct. App. 1978). Similarly, the fact that one person controls two corporations is not sufficient to make the two corporations and the controlling stockholder the same person under the law. Waff Bros., Inc. v. Bank of N.C., N.A., 289 N.C. 198, 221 S.E.2d 273 (1976).

In order to avail itself of the benefits of the alter ego doctrine, thereby piercing the corporate veil, the plaintiff must establish that the corporate entity was used to promote an injustice or fraud. Quarles v. Fuqua Industries, Inc., 504 F.2d 1358 (10th Cir. 1974); Norman v. Del Elia, 111 Ariz. 480, 533 P.2d 537 (1975); Kahili, Inc. v. Yamamoto, 54 Hawaii 267, 506 P.2d 9 (1973); Rosebud Corp. v. Boggio, 39 Colo. App. 84, 88, 561 P.2d 367, 371 (1977). In determining whether it is appropriate to apply the alter ego doctrine, other courts have inquired whether the corporation is undercapitalized, IZE Nantan Bagowa, Ltd. v. Scalia supra; Harris v. Curtis, 87 Cal. Rptr. 614, 8 C.A.3d 837 (1970), and whether the stockholder is using the corporation to further his own private business rather than that of the corporation. House of Koscot Dev. Corp. v. American Line Cosmetics, Inc., 468 F.2d 64 (5th Cir. 1972); Holahan v. Henderson, 277 F. Supp. 890 (W.D. La. 1967), aff’d 394 F.2d 177, cert. denied, 393 U.S. 848 (1968); Kirk v. H.G.P. Corp., 208 Kan. 777, 494 P.2d 1087 (1972).

Our review of the trial transcript reveals that the plaintiff offered no evidence which tended to show that Stephen Blum used the corporate entity to promote his own personal business. Nor did plaintiff offer any evidence concerning the capitalization or solvency of the two corporations. Plaintiff’s only evidence was that its agents, who were aware of the existence of the corporations, dealt with the corporations through the defendant Stephen Blum.

While we are not hesitant to disregard the corporate fiction, Ashland Dumber Company, Inc. v. Hayes, 119 N.H. 440, 402 A.2d[*472] 201 (1979); Peter R. Previte, Inc. v. McAllister Florist, Inc., 113 N.H. 579, 581, 311 A.2d 121, 123 (1973), we will not do so solely on the basis that a corporation is a one-man operation if there is no proof that the defendant conveyed property fraudulently, that he “suppressed the fact of [his] incorporation or [that he] misled the plaintiff as to the corporate assets.” Ashland Lumber Company, supra at 441, 402 A.2d at 202, quoting Peter R. Previte, Inc., supra at 582, 311 A.2d at 123.

Exceptions sustained; judgment against the defendant Stephen Blum vacated.

All concurred.