piercing the corporate veil doctrine (Ohio) · Go Syfert
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piercing the corporate veil doctrine in Ohio

8 Ohio opinions name it 1 courts 1995–2025 2 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
Rco International Corporation v. Clevengergreen
ohioctapp · 2008 · cited in 2 Ohio opinions naming this issue, 2014–2019
2 sentences

2019Corp. v. Clevenger, 180 Ohio App.3d 211, 214 , 2008-Ohio-6823 , 904 N.E.2d 941, ¶ 4, 9-12 (10th Dist.). {¶16} The Supreme Court of Ohio has set forth the elements that must be present in order for a trial court to apply the doctrine of piercing the corporate veil: (1) control over the corporation by those to be held liable was so complete that the corporation has no separate mind, will, or existence of its own, (2) control over the corporation by those to be held liable was exercised in such a manner as to commit fraud or an illegal act against the person seeking to disregard the corporate ent

2019Corp. v. Clevenger, 180 Ohio App.3d 211, 214 , 2008-Ohio-6823 , 904 N.E.2d 941, ¶ 4, 9-12 (10th Dist.). {¶16} The Supreme Court of Ohio has set forth the elements that must be present in order for a trial court to apply the doctrine of piercing the corporate veil: (1) control over the corporation by those to be held liable was so complete that the corporation has no separate mind, will, or existence of its own, (2) control over the corporation by those to be held liable was exercised in such a manner as to commit fraud or an illegal act against the person seeking to disregard the corporate ent

22
Fast Tract Title Servs., Inc. v. Barrygreen
ohioctapp · 2022 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025A plaintiff seeking to recover under the doctrine of piercing the corporate veil is not required to demonstrate fraud in order to meet the second prong of the Beveldere-Dombroski test; a plaintiff can also demonstrate that the defendant committed “an illegal act or a similarly unlawful act.” Fast Tract Title Servs. v. Barry, 2022-Ohio-1943, ¶ 18 (8th Dist.), citing Dombroski, at syllabus. {¶ 37} Hayes argues that the Gouchers committed an unlawful act when they tried or attempted to sell his property without his permission or the title of the property.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Dombroski v. WellPoint, Inc. green
ohio · 2008
2 sentences

2022A plaintiff seeking to recover under the doctrine of piercing the corporate veil is not required to demonstrate fraud in order to meet the second prong of the Beveldere-Dombroski test; a plaintiff can also demonstrate that the defendant committed “an illegal act or a similarly unlawful act.” Dombroski, 119 Ohio St.3d 506 , 2008-Ohio-4827 , 895 N.E.2d 538 , syllabus.

2022A plaintiff seeking to recover under the doctrine of piercing the corporate veil is not required to demonstrate fraud in order to meet the second prong of the Beveldere-Dombroski test; a plaintiff can also demonstrate that the defendant committed “an illegal act or a similarly unlawful act.” Dombroski, 119 Ohio St.3d 506 , 2008-Ohio-4827 , 895 N.E.2d 538 , syllabus.

12022–2022
Minno v. Pro-Fab, Inc. green
ohio · 2009
1 sentence

2016The Court recited, the doctrine of piercing the corporate veil is a “judicial act of imposing personal liability on otherwise immune corporate officers, directors, or shareholders for the corporation's wrongful acts.” Minno, 121 Ohio St.3d 464 at ¶ 8 .

12016–2016
Fancher v. Fancher green
ohioctapp · 1982
2 sentences

2007However, the complaint must contain either direct allegations on every material point necessary to sustain a recovery on any legal theory, even though it may not be the theory suggested or intended by the pleader, or contain allegations from which an inference fairly may be drawn that evidence on these material points will be introduced at trial.’ 5 Wright & Miller, Federal Practice & Procedure: Civil (12969), at 120-123, Section 1216.” Fancher v. Fancher (1982), 8 Ohio App.3d 79, 83 , 8 OBR 111, 455 N.E.2d 1344 . {¶21} A party seeking to pierce the corporate veil is not required to relate the

2007However, the complaint must contain either direct allegations on every material point necessary to sustain a recovery on any legal theory, even though it may not be the theory suggested or intended by the pleader, or contain allegations from which an inference fairly may be drawn that evidence on these material points will be introduced at trial.’ 5 Wright & Miller, Federal Practice & Procedure: Civil (12969), at 120-123, Section 1216.” Fancher v. Fancher (1982), 8 Ohio App.3d 79, 83 , 8 OBR 111, 455 N.E.2d 1344 . {¶21} A party seeking to pierce the corporate veil is not required to relate the

12007–2007
American Hardware Supply v. Alan Supply, Inc. green
ohioctapp · 1989
1 sentence

2001In American Hardware Supply v. Alan Supply, Inc. (1989), 63 Ohio App.3d 838 , 843 , this court applied the piercing the corporate veil standard set forth in Bucyrus-Erie Co. v. Gen.

12001–2001
Belvedere Condominium Unit Owners' Ass'n v. R.E. Roark Companies, Inc. green
ohio · 1993
2 sentences

1995Belvedere, 67 Ohio St.3d at 288 , 617 N.E.2d at 1085-1086 .

1995Belvedere, 67 Ohio St.3d at 288 , 617 N.E.2d at 1085-1086 .

11995–1995

Where else courts name it

NY 27 (2005–2026) IL 23 (1982–2024) PA 20 (1964–2024) NJ 17 (1983–2026) NC 16 (1985–2025) OH 8 (1995–2025) CT 8 (1993–2021) WY 6 (1987–2021) SC 6 (1984–2026) TN 5 (1997–2017) NH 4 (2003–2021) CO 4 (2009–2020) IN 4 (2006–2024) MI 3 (2007–2026) KY 3 (2012–2024) IA 2 (2015–2015) CA 2 (1972–2019) AK 2 (2009–2025) OK 2 (2007–2011) TX 2 (2015–2023) LA 2 (2014–2017) MO 2 (2011–2019) GA 2 (2012–2012) AR 2 (2011–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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