alter ego doctrine in California

2026Co. (1994) 25 Cal.App.4th 1269, 1285, fn. 13 , citing Associated Vendors, Inc. v. Oakland Meat Co. (1962) 210 Cal. App. 2d 825 .) As to the requirement for an inequitable result, “[t]he essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach an equitable result.’ [Citation.] Thus the corporate form will be disregarded only in narrowly defined circumstances and only when the ends of justice so require.” (Mesler, supra, 39 Cal.3d at p. 301

2025Guiding Principles “The alter ego doctrine arises when a plaintiff comes into court claiming that an opposing party is using the corporate form unjustly and in derogation of the plaintiff’s interests.” (Mesler v. Bragg Management Co. (1985) 39 Cal.3d 290, 300 (Mesler).) The courts “will disregard the corporate form, or, to use accepted terminology, ‘pierce the corporate veil,’ whenever necessary to prevent fraud or to achieve equity.” (Lyons v. Stevenson (1977) 65 Cal.App.3d 595, 606 .) “Because society recognizes the benefits of allowing persons and organizations to limit their business risks

2026(See Sonora Diamond, supra, 83 Cal.App.4th at p. 547 [noting that it is normal for an owner of an unprofitable company to provide ongoing financial support because “[i]f such an owner wishes to remain in business in the anticipation of ultimately turning a profit, one option is to use its own assets to make up for the business's inability to generate sufficient revenue to cover all its costs”].) In sum, C4 has not shown the evidence would compel a finding in its favor on the second factor of the alter ego test as a matter of law.

2026“Ordinarily, a corporation is regarded as a legal entity, separate and distinct from its stockholders, officers and directors, with separate and distinct liabilities and obligations.” (Sonora Diamond Corp v. Superior Court (2000) 83 Cal.App.4th 523, 538 (Sonora).) But under the alter ego doctrine, “[a] corporate identity may be disregarded — the ‘corporate veil’ pierced — where an abuse of the corporate privilege justifies holding the 6 equitable ownership of a corporation liable for the actions of the corporation.” (Id. at p. 538.) The doctrine “is an extreme remedy, sparingly used.” (Id. at

2026Second, there must be an inequitable result if the acts in question are treated as those of the corporation alone.” ’ ” (Hacker v. Fabe (2023) 92 Cal.App.5th 1267 , 1276.) “The plaintiff has the burden of establishing both requirements.” (Angel Lynn Realty, Inc. v. George (2025) 114 Cal.App.5th 655 , 667.) “Among the many factors relevant in applying the alter ego doctrine are ‘one individual’s ownership of all stock in a corporation; use of the same office or business location; commingling of funds and other assets of the individual and the corporation; an individual holding out that he is pe

2024(JPV, at p. 189.) “The essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach an equitable result.’ [Citation.] Thus the corporate form will be disregarded only in narrowly defined circumstances and only when the ends of justice so require.” (Mesler v. Bragg Management Co. (1985) 39 Cal.3d 290, 301 ; see also JPV, at p. 189 [doctrine is an “ ‘ “extreme remedy, sparingly used” ’ ”]; Hasso v. Hapke (2014) 227 Cal.App.4th 107, 155 [same].)

2026Co. (1994) 25 Cal.App.4th 1269, 1285, fn. 13 , citing Associated Vendors, Inc. v. Oakland Meat Co. (1962) 210 Cal. App. 2d 825 .) As to the requirement for an inequitable result, “[t]he essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach an equitable result.’ [Citation.] Thus the corporate form will be disregarded only in narrowly defined circumstances and only when the ends of justice so require.” (Mesler, supra, 39 Cal.3d at p. 301

2025(Id. at pp. 811–812; Sonora Diamond Corp. v. 20 Superior Court (2000) 83 Cal.App.4th 523, 539 (Sonora).) Additionally, “[t]here also must be some conduct amounting to bad faith that makes it inequitable for [the defendant] to hide behind the corporate form.” (Leek, supra, 194 Cal.App.4th at p. 418 .) No single factor is determinative, and courts “must look at all the circumstances to determine whether the doctrine should be applied.” (Sonora, supra, 83 Cal.App.4th at p. 539 ; Zoran, supra, 185 Cal.App.4th at p. 812 .) Whether both prongs of the alter ego test are met “is primarily one for the

2026The court thus has constructed for purposes of imposing liability an entity unknown to any secretary of state comprising assets and liabilities of two or more legal personalities; endowed that entity with the assets of both, and charged it with the liabilities of one or both.”’” (Las Palmas Associates v. Las Palmas Center Associates (1991) 235 Cal.App.3d 1220, 1249-1250 .) Vaya argues the Commission lacks jurisdiction to impose the alter ego doctrine because it is a common law equitable doctrine applied by the courts pursuant to their constitutional powers.

2026Co. (1994) 25 Cal.App.4th 1269, 1285, fn. 13 , citing Associated Vendors, Inc. v. Oakland Meat Co. (1962) 210 Cal. App. 2d 825 .) As to the requirement for an inequitable result, “[t]he essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach an equitable result.’ [Citation.] Thus the corporate form will be disregarded only in narrowly defined circumstances and only when the ends of justice so require.” (Mesler, supra, 39 Cal.3d at p. 301

2021Co. (1957) 153 39 Cal.App.2d 404, 415 (Engineering Service Corp.).) “It is enough if the recognition of the two entities as separate would result in an injustice.” (Gordon v. Aztec Brewing Co. (1949) 33 Cal.2d 514, 523 (Gordon); see also Automotriz del Golfo de California S.A. de C.V. v. Resnick (1957) 47 Cal.2d 792, 796 (Automotriz).) On appeal, we apply the substantial evidence standard in reviewing a trial court’s finding that the alter ego doctrine applies.

2016V. v. Resnick (1957) 47 Cal.2d 792, 796 (Automotriz); Leek v. Cooper (2011) 194 Cal.App.4th 399, 415 (Leek).) The factors to be considered in applying the alter ego doctrine include “ ‘ “[c]ommingling of funds and other assets, failure to segregate funds of the separate entities, and the unauthorized diversion of corporate funds or assets to other than corporate uses . . . ; . . . the treatment by an individual of the assets of the corporation as his own . . . ; . . . the failure to obtain authority to issue stock or to subscribe to or issue the same; . . . the holding out by an individual tha

2026However, the SR defendants also assert that 11 plaintiff advanced a reverse veil piercing alter ego theory, which “seeks to satisfy the debt of an individual through the assets of an entity of which the individual is an insider.” (Curci Investments, LLC v. Baldwin (2017) 14 Cal.App.5th 214, 221 [observing that the alter ego doctrine is “traditional veil piercing”].) Reverse veil piercing still requires pleading a unity of interest between an individual and the relevant corporation, as well as an inequitable result.

2025(Ibid., italics added; see also id. at p. 301 [“The law of this state is that the separate corporate entity will not be honored where to do so would be to defeat the rights and equities of third persons.”]; Curci Investments, LLC v. Baldwin (2017) 14 Cal.App.5th 214, 221 [“ ‘The alter ego doctrine prevents individuals or other corporations from misusing the corporate laws by the device of a sham corporate entity formed for the purpose of committing fraud or other misdeeds.’ ”].) Contrary to the assertion of Kahn and Kahn, Inc., the allegations in the FAC that were admitted by the court’s impos

2023In certain circumstances the court will disregard the corporate entity and will hold the individual shareholders liable for the actions of the corporation[.]’ ” (Greenspan v. LADT LLC (2010) 191 Cal.App.4th 486, 510 (Greenspan).) Under both California and Delaware law, the alter ego doctrine extends to LLCs (see Corp. Code, § 17703.04, 16 subd. (b); NetJets Aviation, Inc. v. LHC Communications, LLC (2d Cir. 2008) 537 F.3d 168, 178 (NetJets)), and generally requires the proponent to demonstrate two elements: (1) a unity of interest and ownership such that the separate personalities of the corpo

2023Unity of Interest and Ownership Among the many factors relevant in applying the alter ego doctrine are “one individual’s ownership of all stock in a corporation; use of the same office or business location; commingling of funds and other assets of the individual and the corporation; an individual holding out that he is personally liable for debts of the corporation; identical directors and officers; failure to maintain minutes or adequate corporate records; disregard of corporate formalities; absence of corporate assets and inadequate capitalization; and the use of a corporation as a mere shel

2025(Id. at pp. 811–812; Sonora Diamond Corp. v. 20 Superior Court (2000) 83 Cal.App.4th 523, 539 (Sonora).) Additionally, “[t]here also must be some conduct amounting to bad faith that makes it inequitable for [the defendant] to hide behind the corporate form.” (Leek, supra, 194 Cal.App.4th at p. 418 .) No single factor is determinative, and courts “must look at all the circumstances to determine whether the doctrine should be applied.” (Sonora, supra, 83 Cal.App.4th at p. 539 ; Zoran, supra, 185 Cal.App.4th at p. 812 .) Whether both prongs of the alter ego test are met “is primarily one for the

2025(Id. at pp. 811–812; Sonora Diamond Corp. v. 20 Superior Court (2000) 83 Cal.App.4th 523, 539 (Sonora).) Additionally, “[t]here also must be some conduct amounting to bad faith that makes it inequitable for [the defendant] to hide behind the corporate form.” (Leek, supra, 194 Cal.App.4th at p. 418 .) No single factor is determinative, and courts “must look at all the circumstances to determine whether the doctrine should be applied.” (Sonora, supra, 83 Cal.App.4th at p. 539 ; Zoran, supra, 185 Cal.App.4th at p. 812 .) Whether both prongs of the alter ego test are met “is primarily one for the

2023The law The Supreme Court tells us that “[t]he essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach 9 an equitable result.’ ” (Mesler v. Bragg Management Co. (1985) 39 Cal.3d 290, 301 (Mesler).) Another court explains the equitable doctrine: “ ‘A corporate identity may be disregarded—the “corporate veil” pierced—where an abuse of the corporate privilege justifies holding the equitable ownership of a corporation liable for the actions

2023However, given that the subscribers are required to appoint the attorney-in-fact as managerial agent, the ‘ownership’ element of the alter ego doctrine is not applicable in this context.” (Tran, supra, 104 Cal.App.4th at p. 1219, fn. 7 ; see also Troyk v. Farmers Group, Inc. (2009) 171 Cal.App.4th 1305, 1341-43 [attorney-in- fact can be held liable as an alter ego even though there is no shared ownership].) 11 alter ego claim in this context, holding: “When a reciprocal insurer functions as a mere instrumentality of an attorney-in-fact in the conduct of a unified insurance business, it would b

2024(Stark v. Coker (1942) 20 Cal.2d 839, 846 ; Dow Jones Co. v. Avenel, supra, 151 Cal.App.3d at pp. 147- 148 [“the ‘constitutional guaranty of the right to a jury trial does not apply to actions involving the application of equitable doctrines’ ” such as the alter ego doctrine].) In response to Firouzi’s alter ego arguments in his new trial motion, the court ruled there was sufficient evidence for the jury to impose individual 18 liability on him.

2021(Las Palmas, supra, 235 Cal.App.3d at p. 1248 ; Stark v. Coker (1942) 20 Cal.2d 839, 846 [“the doctrine is essentially an equitable one and for that reason is particularly within the province of the trial court”].) The doctrine pierces a corporation’s ordinary status as a legal entity distinct from its shareholders, officers, and directors “where an abuse of the corporate privilege justifies holding the equitable ownership of a corporation liable for the actions of the corporation.” (Sonora Diamond, supra, 83 Cal.App.4th at p. 538 .) “Under the alter ego doctrine, . . . when the corporate form

2024The Williams plaintiffs misapprehend the alter ego doctrine. “‘“Under the alter ego doctrine, . . . where a corporation is used by an individual or individuals, or by another corporation, to perpetrate fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, a court may disregard the corporate entity and treat the corporation’s acts as if they were done by the persons actually controlling the corporation.”’” a “‘representative’” is narrowly defined as “a person or entity that is either . . . : [¶] (1) [a] conservator, trustee, or other representative of the estate

2023Citing his declaration, Binder asserted that, because he (“in his individual capacity and/or as a fictitious business (d/b/a)”) did not sell any jewelry after August 31, 2014, he (ditto) did not earn any revenues, income, or profit during “the applicable limitations period.” Thus, Binder argued, Straiton could not establish “any ascertainable damages during the applicable limitations period, an essential element to his claims.” KBSI argued that it “has never been a party to any contract with Straiton” and that the court in Postal Instant Press, Inc. v. Kaswa Corp. (2008) 162 Cal.App.4th 1510,

2022(Minifie v. Rowley (1921) 187 Cal. 481, 488 ; Wenban 8 Estate, Inc. v. Hewlett (1924) 193 Cal. 675, 697 ; Gordon v. Aztec Brewing Co. (1949) 33 Cal.2d 514, 523 ; see Higgins v. Cal. Petroleum etc. Co. (1898) 122 Cal. 373, 376 .) More recent Court of Appeal decisions have expressly held that “ ‘[a]pplication of the alter ego doctrine does not depend upon pleading or proof of fraud.’ [Citations.] The doctrine can be invoked when adherence to the fiction of the separate existence of the corporation would promote injustice [citation] or bring about inequitable results.” (Misik v. D’Arco (2011) 197

2018The alter ego doctrine is an equitable principle that elevates substance over form in order to prevent an inequitable result arising from unjustifiably observing a corporation's separate existence. ( Capon , supra , 193 Cal.App.4th at p. 357 , 122 Cal.Rptr.3d 536 .) The doctrine is applied, and a party other than the corporation is liable for the corporation's acts, when recognition of the corporate structure would "sanction a fraud or promote injustice." ( Minifie v. Rowley (1921) 187 Cal. 481 , 487, 202 P. 673 ; accord, Gopal v. Kaiser Foundation Health Plan, Inc. (2016) 248 Cal.App.4th 425

2014(Wood v. Elling Corp. (1977) 20 Cal.3d 353, 365, fn. 9 .) The test for this requirement looks to whether an unjust or inequitable result would follow if the acts in question are treated as those of the corporation alone.

2014(Wood v. Elling Corp. (1977) 20 Cal.3d 353, 365 .) In the case of a trust, the question is whether the trustee lacks independence and simply carries out the bidding of the equitable owner of the trust property.

2011Co. (2007) 154 Cal.App.4th 71,76 [ 64 Cal.Rptr.3d 260 ] [“An individual who has obtained the benefits of corporate limited liability will not be permitted to repudiate corporate existence just because the corporation has become an inconvenience.”]; Aladdin Oil Corp. v. Perluss (1964) 230 Cal.App.2d 603, 614 [ 41 Cal.Rptr. 239 ] [“The alter ego doctrine is applied to avoid inequitable results not to eliminate the consequences of corporate operations. [Citations.]”].) 12 The trial court did not identify in its statement of decision, and defendants have not identified on appeal, any inequitable r

2011Co. (2007) 154 Cal.App.4th 71,76 [ 64 Cal.Rptr.3d 260 ] [“An individual who has obtained the benefits of corporate limited liability will not be permitted to repudiate corporate existence just because the corporation has become an inconvenience.”]; Aladdin Oil Corp. v. Perluss (1964) 230 Cal.App.2d 603, 614 [ 41 Cal.Rptr. 239 ] [“The alter ego doctrine is applied to avoid inequitable results not to eliminate the consequences of corporate operations. [Citations.]”].) 12 The trial court did not identify in its statement of decision, and defendants have not identified on appeal, any inequitable r

2025(Id. at pp. 811–812; Sonora Diamond Corp. v. 20 Superior Court (2000) 83 Cal.App.4th 523, 539 (Sonora).) Additionally, “[t]here also must be some conduct amounting to bad faith that makes it inequitable for [the defendant] to hide behind the corporate form.” (Leek, supra, 194 Cal.App.4th at p. 418 .) No single factor is determinative, and courts “must look at all the circumstances to determine whether the doctrine should be applied.” (Sonora, supra, 83 Cal.App.4th at p. 539 ; Zoran, supra, 185 Cal.App.4th at p. 812 .) Whether both prongs of the alter ego test are met “is primarily one for the

2023“The essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to . . . is that liability is imposed to reach an equitable result[ ]’ . . . when the ends of justice so require.” (Mesler v. Bragg Management Co., supra, 39 Cal.3d at p. 301 .) Some courts have stated that “[d]ifficulty in enforcing a judgment does not alone satisfy this element” and that “[t]here also must be some conduct amounting to bad faith that makes it inequitable for [the individual] to hide behind the corporate form.” (Leek v. Cooper, supra, 194 Cal.App.4th at p. 418 ; see Sonora Diamond Corp

2026Under the alter ego doctrine, however, where a corporation is used by an individual or individuals . . . to perpetrate fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, a court may disregard the corporate entity and treat the corporation’s acts as if they were done by the persons actually controlling the corporation.” ’ ” (Toho-Towa Co., Ltd. v. Morgan Creek Productions, Inc. (2013) 217 Cal.App.4th 1096 , 1106–1107.) “ ‘ “In California, two conditions must be met before the alter ego doctrine will be invoked.

2024The Williams plaintiffs misapprehend the alter ego doctrine. “‘“Under the alter ego doctrine, . . . where a corporation is used by an individual or individuals, or by another corporation, to perpetrate fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, a court may disregard the corporate entity and treat the corporation’s acts as if they were done by the persons actually controlling the corporation.”’” a “‘representative’” is narrowly defined as “a person or entity that is either . . . : [¶] (1) [a] conservator, trustee, or other representative of the estate

2025Co. v. Gardner (1992) 9 Cal.App.4th 1205, 1212 .) There are two general requirements to pierce the corporate veil: “ ‘(1) that there be such unity of interest and ownership that the separate personalities of the corporation and the individual [or other entity] no longer exist and (2) that, if the acts are treated as those of [one] corporation alone, an inequitable result will follow.’ ” (Mesler, supra, 39 Cal.3d at p. 300 .) “There is no litmus test to determine when the corporate veil will be pierced; rather the result will depend on the circumstances of each particular case.” (Ibid.) “The es

2016Co. v. Gardner (1992) 9 Cal.App.4th 1205, 1212-1213 [ 11 Cal.Rptr.2d 918 ].) In evaluating the two requirements of the alter ego doctrine, courts look to the totality of the circumstances bearing on the relationship between the parent and its subsidiary.

2000(Roman Catholic Archbishop v. Superior Court (1971) 15 Cal.App.3d 405, 411 [ 93 Cal.Rptr. 338 ].) Under the alter ego doctrine, then, when the corporate form is used to perpetrate a fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, the courts will ignore the corporate entity and deem the corporation’s acts to be those of the persons or organizations actually controlling the corporation, in most instances the equitable owners.

2000(Roman Catholic Archbishop v. Superior Court (1971) 15 Cal.App.3d 405, 411 [ 93 Cal.Rptr. 338 ].) Under the alter ego doctrine, then, when the corporate form is used to perpetrate a fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, the courts will ignore the corporate entity and deem the corporation’s acts to be those of the persons or organizations actually controlling the corporation, in most instances the equitable owners.

2016That is because, under California law, a parent corporation or an individual’s ownership of a subsidiary is necessary for application of the alter ego doctrine (CADC/RADC, supra, 235 Cal.App.4th at p. 789 ), but it is not sufficient (Leek v. Cooper (2011) 194 Cal.App.4th 399, 415 [ 125 Cal.Rptr.3d 56 ]; Meadows v. Emett & Chandler (1950) 99 Cal.App.2d 496, 499 [ 222 P.2d 145 ]; Hollywood Cleaning & Pressing Co. v. Hollywood Laundry Service, Inc. (1932) 217 Cal. 124, 129 [ 17 P.2d 709 ]; Erkenbrecher v. Grant (1921) 187 Cal. 7, 11 [ 200 P. 641 ]).

2016That is because, under California law, a parent corporation or an individual’s ownership of a subsidiary is necessary for application of the alter ego doctrine (CADC/RADC, supra, 235 Cal.App.4th at p. 789 ), but it is not sufficient (Leek v. Cooper (2011) 194 Cal.App.4th 399, 415 [ 125 Cal.Rptr.3d 56 ]; Meadows v. Emett & Chandler (1950) 99 Cal.App.2d 496, 499 [ 222 P.2d 145 ]; Hollywood Cleaning & Pressing Co. v. Hollywood Laundry Service, Inc. (1932) 217 Cal. 124, 129 [ 17 P.2d 709 ]; Erkenbrecher v. Grant (1921) 187 Cal. 7, 11 [ 200 P. 641 ]).

2021It is true that “[t]he unity of ownership and interest demonstrated in the two personalities is reflected in the ownership by the individual in the stock of the corporation; when it is absent, the alter ego doctrine is generally unavailable.” (CADC/RADC Venture 2011-1 LLC v. Bradley (2015) 235 Cal.App.4th 775, 788 , citing Riddle v. Leuschner (1959) 51 Cal.2d 574, 580 [finding no “unity of interest 15 and ownership” between individual defendant and alleged alter ego corporations where it was “undisputed that he held none of the stock, and there is no evidence that he had any interest as an own

1961In Riddle v. Leuschner, supra, 51 Cal.2d 574, 581 , it was held that: “. . . two or more shareholders of a corporation may be liable as principals or partners under the alter ego principle.” Counsel for appellants concedes that the amended complaint under causes of action two and three, as against defendant Palm Springs Homes Incorporated, does state a cause of action.

2026The SAC’s claims against the SR defendants were not based on an alter ego theory In general, the “two requirements for applying the alter ego doctrine are that (1) there is such a unity of interest and ownership between the corporation and the individual or organization controlling it that their separate personalities no longer exist, and (2) failure to disregard the corporate entity would sanction a fraud or promote injustice.” (Communist Party v. 522 Valencia, Inc. (1995) 35 Cal.App.4th 980, 993 .) Thus, “the plaintiff must plead and prove such a unity of interest and ownership that the sepa

2024The Williams plaintiffs misapprehend the alter ego doctrine. “‘“Under the alter ego doctrine, . . . where a corporation is used by an individual or individuals, or by another corporation, to perpetrate fraud, circumvent a statute, or accomplish some other wrongful or inequitable purpose, a court may disregard the corporate entity and treat the corporation’s acts as if they were done by the persons actually controlling the corporation.”’” a “‘representative’” is narrowly defined as “a person or entity that is either . . . : [¶] (1) [a] conservator, trustee, or other representative of the estate

2024(JPV, at p. 189.) “The essence of the alter ego doctrine is that justice be done. ‘What the formula comes down to, once shorn of verbiage about control, instrumentality, agency, and corporate entity, is that liability is imposed to reach an equitable result.’ [Citation.] Thus the corporate form will be disregarded only in narrowly defined circumstances and only when the ends of justice so require.” (Mesler v. Bragg Management Co. (1985) 39 Cal.3d 290, 301 ; see also JPV, at p. 189 [doctrine is an “ ‘ “extreme remedy, sparingly used” ’ ”]; Hasso v. Hapke (2014) 227 Cal.App.4th 107, 155 [same].)

2022Second, there must be an inequitable result if the acts in question are treated as those of the corporation alone.’ [Citations.]” (Hasso, supra, 227 Cal.App.4th at p. 155 .) Courts consider a number of factors when determining whether to apply the alter ego doctrine, including but not limited to, “ ‘ “[c]ommingling of funds and other assets, failure to 37 segregate funds of the separate entities, and the unauthorized diversion of corporate funds or assets to other than corporate uses . . . ; . . . the treatment by an individual of the assets of the corporation as his own . . . ; . . . the fail

2022(Minifie v. Rowley (1921) 187 Cal. 481, 488 ; Wenban 8 Estate, Inc. v. Hewlett (1924) 193 Cal. 675, 697 ; Gordon v. Aztec Brewing Co. (1949) 33 Cal.2d 514, 523 ; see Higgins v. Cal. Petroleum etc. Co. (1898) 122 Cal. 373, 376 .) More recent Court of Appeal decisions have expressly held that “ ‘[a]pplication of the alter ego doctrine does not depend upon pleading or proof of fraud.’ [Citations.] The doctrine can be invoked when adherence to the fiction of the separate existence of the corporation would promote injustice [citation] or bring about inequitable results.” (Misik v. D’Arco (2011) 197

2021Co. (1957) 153 39 Cal.App.2d 404, 415 (Engineering Service Corp.).) “It is enough if the recognition of the two entities as separate would result in an injustice.” (Gordon v. Aztec Brewing Co. (1949) 33 Cal.2d 514, 523 (Gordon); see also Automotriz del Golfo de California S.A. de C.V. v. Resnick (1957) 47 Cal.2d 792, 796 (Automotriz).) On appeal, we apply the substantial evidence standard in reviewing a trial court’s finding that the alter ego doctrine applies.

2022Code, § 3528; see, e.g., Webber v. Inland Empire Investments, Inc. ( 74 Cal.App.4th 884 , 900–901 [noting, in the context of the alter ego doctrine, that a court may disregard a corporate entity used 7 to accomplish a wrongful purpose].) In fact, State Fund’s written endorsement expressly advised Perez that its agreement to change the name of its insured to ALP Inc. did not alter any of his contractual obligations.3 There could have been no conceivable confusion or “inequit[y.]” Perez was indisputably on notice that his debt for both policy periods was assigned to Northern, and there is no “gl

2013Analysis The trial court began its alter ego analysis by quoting from Mesler v. Bragg Management Co., supra, 39 Cal.3d 290 for the proposition that " 'the essence of the alter ego doctrine is that justice be done . . . [and] that liability is imposed to reach an equitable result.' " It cited to the appellate court's statement in Webber v. Inland Empire Investments, Inc. (1999) 74 Cal.App.4th 884 that the doctrine is limited and only invoked " 'where recognition of the corporate form would work an injustice to a third person.' " Given these comments, it is evident the trial court rightly focuse

2023Partnership (2013) 222 Cal.App.4th 811, 815 (Relentless).) “The decision to grant an amendment lies in the sound discretion of the trial court.” (Ibid.) “ ‘The alter ego doctrine arises when a plaintiff comes into court claiming that an opposing party is using the corporate form unjustly and in derogation of the plaintiff’s interests. . . .

2023Inequitable Result Application of the alter ego doctrine also requires “a finding that the facts are such that adherence to the fiction of the separate existence of the corporation would sanction a fraud or promote injustice. [Citation.] The test for this requirement is that if the acts are treated as those of the corporation alone, it will produce an unjust or inequitable result.” (Misik, supra, 197 Cal.App.4th at p. 1073 .) “An inequitable result does not require a wrongful intent.” (Relentless, supra, 222 Cal.App.4th at p. 813 .) We agree with the Koettings that difficulty in enforcing a ju

2026“Ordinarily, a corporation is regarded as a legal entity, separate and distinct from its stockholders, officers and directors, with separate and distinct liabilities and obligations.” (Sonora Diamond Corp v. Superior Court (2000) 83 Cal.App.4th 523, 538 (Sonora).) But under the alter ego doctrine, “[a] corporate identity may be disregarded — the ‘corporate veil’ pierced — where an abuse of the corporate privilege justifies holding the 6 equitable ownership of a corporation liable for the actions of the corporation.” (Id. at p. 538.) The doctrine “is an extreme remedy, sparingly used.” (Id. at

2022Amending a judgment to add an alter ego is an equitable procedure (Highland Springs, supra, 244 Cal.App.4th at p. 280 ), and “[t]he essence of the alter ego doctrine is that justice be done” (Mesler, supra, 39 Cal.3d at p. 301 ).

2023Butler further explained: “In applying the alter ego doctrine, no particular findings are necessary, but the conditions under which a corporate entity should be ignored vary according to the circumstances of each case.” (Id. at p. 146.) Alter ego “is an equitable doctrine and, though courts have justified its application through consideration of many factors, their basic motivation is to assure a just and equitable result.” (Alexander v. Abbey of the Chimes (1980) 104 Cal.App.3d 39, 48 .) Here, there was evidence STI has been unable to collect on the judgment because Quarles shut down Bedford

2014The Alter Ego Doctrine and the Standard of Review “[T]he conditions under which the corporate entity may be disregarded vary according to the circumstances in each case and the matter is particularly within the province of the trial court. [Citations.] This is because the determination of whether a corporation is an alter ego of an individual is ordinarily a question of fact.” (Alexander v. Abbey of the Chimes (1980) 104 Cal.App.3d 39, 46 .) There are two requirements for disregarding the corporate entity under the alter ego doctrine.