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9 Pennsylvania opinions name it 2 courts 2021–2026 9 in the last five years
The cases below were cited by Pennsylvania 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.
| Case | Followed | Cited |
|---|---|---|
Lumax Industries, Inc. v. Aultmangreen2 sentences2026The Superior Court expressed that, in Lumax, this Court “cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs[,] and use of the corporate form to perpetrate a fraud.” Id. (alteration in original) (citation and internal quotation marks omitted). 2026The Superior Court expressed that, in Lumax, this Court “cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs[,] and use of the corporate form to perpetrate a fraud.” Id. (alteration in original) (citation and internal quotation marks omitted). | 3 | 7 |
Ashley v. Ashleygreen2 sentences2023In Ashley [v. Ashley, 393 A.2d 637, 641 (Pa. 1978)], we held that the corporate form may be disregarded “whenever one in control of a corporation uses that control, or uses the corporate assets, to further his or her own personal interests.” And in Lumax[ Indus., Inc. v. Aultman, 669 A.2d 893, 895 (Pa. 1995)], we cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: “undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs, and use of the corporate form to perpetrate a fraud.” Mortim 2023In Ashley v. Ashley, 393 A.2d 637, 641 (Pa. 1978), we held that the corporate form may be disregarded “whenever one in control of a corporation uses that control, or uses the corporate assets, to further his or her own personal interests.” And in Lumax Indus., Inc. v. Aultman, 669 A.2d 893, 895 (Pa. 1995), we cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: “undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs, and use of the corporate form to perpetrate a fraud.” Mortimer v | 2 | 3 |
LSREF2 Clover Property 4, LLC v. Festival Retail Fund 1, LPgreen2 sentences2021Enterprise liability may apply when there is “such unity of interest and ownership that the separate personalities of the corporation and the individual no longer exist” and, “if the acts are treated as those of the corporation alone, an inequitable result will follow.” LSREF23 Clover Prop. 4, LLC v. Festival Retail Fund 1, LP, 208 Cal. Rptr.3d 200, 212 (Cal. Ct. App. 2016). 82 Pertuis, 817 S.E.2d at 281-82 . 83 Id. at 280 . 84 See supra n.73. [J-103A-2020 and J-103B-2020] - 31 the blurring of the entities’ legal distinctions.”85 “If any general rule can be laid down, it is that a corporation 2021Enterprise liability may apply when there is “such unity of interest and ownership that the separate personalities of the corporation and the individual no longer exist” and, “if the acts are treated as those of the corporation alone, an inequitable result will follow.” LSREF23 Clover Prop. 4, LLC v. Festival Retail Fund 1, LP, 208 Cal. Rptr.3d 200, 212 (Cal. Ct. App. 2016). 82 Pertuis, 817 S.E.2d at 281-82 . 83 Id. at 280 . 84 See supra n.73. [J-103A-2020 and J-103B-2020] - 31 the blurring of the entities’ legal distinctions.”85 “If any general rule can be laid down, it is that a corporation | 2 | 2 |
Wedner Unemployment Compensation Casegreen2 sentences2021Our Superior Court has observed that “there appears to be no clear test or settled rule in 9 Wedner v. Unemployment Bd. of Review, 296 A.2d 792, 794 (Pa. 1972). 10 Commonwealth by Shapiro v. Golden Gate Nat’l Senior Care LLC, 194 A.3d 1010, 1034-35 (Pa. 2018) (cleaned up). 11 Village at Camelback Prop. 2021Our Superior Court has observed that “there appears to be no clear test or settled rule in 9 Wedner v. Unemployment Bd. of Review, 296 A.2d 792, 794 (Pa. 1972). 10 Commonwealth by Shapiro v. Golden Gate Nat’l Senior Care LLC, 194 A.3d 1010, 1034-35 (Pa. 2018) (cleaned up). 11 Village at Camelback Prop. | 2 | 2 |
Miners, Inc. v. Alpine Equipment Corp.green2 sentences2021Corp., 722 A.2d 691, 695 (Pa. Super. 1998) (emphasis in original). 26 See id. [J-103A-2020 and J-103B-2020] - 11 merely speculated that this Court eventually would embrace the theory. 2021Corp., 722 A.2d 691, 695 (Pa. Super. 1998) (emphasis in original). 26 See id. [J-103A-2020 and J-103B-2020] - 11 merely speculated that this Court eventually would embrace the theory. | 2 | 2 |
Commonwealth v. Golden Gate Nat'l Senior Care LLCgreen2 sentences2021Our Superior Court has observed that “there appears to be no clear test or settled rule in 9 Wedner v. Unemployment Bd. of Review, 296 A.2d 792, 794 (Pa. 1972). 10 Commonwealth by Shapiro v. Golden Gate Nat’l Senior Care LLC, 194 A.3d 1010, 1034-35 (Pa. 2018) (cleaned up). 11 Village at Camelback Prop. 2021Our Superior Court has observed that “there appears to be no clear test or settled rule in 9 Wedner v. Unemployment Bd. of Review, 296 A.2d 792, 794 (Pa. 1972). 10 Commonwealth by Shapiro v. Golden Gate Nat’l Senior Care LLC, 194 A.3d 1010, 1034-35 (Pa. 2018) (cleaned up). 11 Village at Camelback Prop. | 2 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Mortimer, R., Aplt. v. McCool, M.
green
2 sentences2023In Lumax, the Supreme Court had “cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: ‘undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs[,] and use of the corporate form to perpetrate a fraud.’” Mortimer, 255 A.3d at 268 (quoting Lumax, 669 A.2d at 895). 2023In Lumax, the Supreme Court had “cited favorably the Commonwealth Court’s enumeration of factors relevant to the piercing inquiry: ‘undercapitalization, failure to adhere to corporate formalities, substantial intermingling of corporate and personal affairs[,] and use of the corporate form to perpetrate a fraud.’” Mortimer, 255 A.3d at 268 (quoting Lumax, 669 A.2d at 895 ). | 4 | 2023–2023 |
Finkel ex rel. Estate of Atomica Design Group, Inc. v. WeVeel LLC (In re Atomica Design Group, Inc.)
green
2 sentences2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). 2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). | 2 | 2021–2021 |
Nursing Home Consultants, Inc. v. Quantum Health Services, Inc.
green
2 sentences2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). 2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). | 2 | 2021–2021 |
Pertuis v. Front Roe Restaurants, Inc.
green
2 sentences2021The Colorado court utilized “alter ego” terminology, effectively translating the above framework into the requirement that the creditor must establish that both the debtor corporation and the sister corporation against whom relief was sought were alter egos of the common owners.81 In Pertuis, supra, the South Carolina Supreme Court “formally recognize[d]” the “single business enterprise theory,” holding that the same equitable principles that guide the piercing inquiry generally should govern in the single-entity context.82 However, it cautioned that “corporations are often formed for the purp 2021The Colorado court utilized “alter ego” terminology, effectively translating the above framework into the requirement that the creditor must establish that both the debtor corporation and the sister corporation against whom relief was sought were alter egos of the common owners.81 In Pertuis, supra, the South Carolina Supreme Court “formally recognize[d]” the “single business enterprise theory,” holding that the same equitable principles that guide the piercing inquiry generally should govern in the single-entity context.82 However, it cautioned that “corporations are often formed for the purp | 2 | 2021–2021 |
Schwab v. McDonald (In Re LMcD, LLC)
green
2 sentences2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). 2021Ark. 1996) (“Conceptually, a triangular pierce results from a sequential application of the traditional piercing doctrine and the ‘reverse piercing’ doctrine . . . .”); cf. In re Atomica, 556 B.R. at 175 n.34 (citing In re LMcD, 405 B.R. at 565 ; Nursing Home Consultants, 926 F. Supp. at 840 n.12) (“The single entity theory has been compared to ‘triangular piercing,’ whereby one entity’s liability are imposed first upon its shareholders through veil piercing and then upon a commonly owned corporation through ‘reverse piercing.’”). | 2 | 2021–2021 |
Miller v. Brass Rail Tavern, Inc.
green
2 sentences2021In the realm of limited liability companies, that factor is inappropriate, because informality of organization and operation is both common and desired.” 52 Brief for Appellees at 36 (quoting Lumax, 669 A.2d at 895 ) (our emphasis). 53 702 A.2d 1072 (Pa. Super. 1997). [J-103A-2020 and J-103B-2020] - 21 Court affirmed the trial court’s refusal to pierce a tavern’s veil to reach its lone individual owner, despite the fact that the tavern’s only valuable asset was the liquor license— financed by a note held by the owner. 2021In the realm of limited liability companies, that factor is inappropriate, because informality of organization and operation is both common and desired.” 52 Brief for Appellees at 36 (quoting Lumax, 669 A.2d at 895 ) (our emphasis). 53 702 A.2d 1072 (Pa. Super. 1997). [J-103A-2020 and J-103B-2020] - 21 Court affirmed the trial court’s refusal to pierce a tavern’s veil to reach its lone individual owner, despite the fact that the tavern’s only valuable asset was the liquor license— financed by a note held by the owner. | 2 | 2021–2021 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.