alter ego doctrine (New Mexico) · Go Syfert
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alter ego doctrine in New Mexico

7 New Mexico opinions name it 1 courts 1976–2025 1 in the last five years

The cases below were cited by New Mexico 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 (19)

CaseFollowedCited
Scott Graphics, Inc. v. Mahaneygreen
nmctapp · 1976 · cited in 3 New Mexico opinions naming this issue, 1983–2011
2 sentences

2011See Mahaney, 89 N.M. at 211 , 549 P.2d at 626 (stating that the 12 determination of alter ego describes situations where “the shareholders have so 13 manipulated the corporation to further their own individual interests that the identity 14 of the corporation has merged into its shareholders”); Harlow, 100 N.M. at 382 , 671 15 P.2d at 43 (stating that it must be proven that the “corporation was operated not in a 16 legitimate fashion to serve the valid goals and purposes of that corporation but that it 17 functioned under the domination and control and for the purposes of some dominant 18 part

2005Liability based on an alter ego theory lies "where the shareholders have so manipulated the corporation to further their own individual interests that the identity of the corporation has merged into its shareholders." Scott Graphics, Inc. v. Mahaney, 89 N.M. 208, 211 , 549 P.2d 623, 626 (Ct.App.1976).

23
Harlow v. Fibron Corp.green
nmctapp · 1983 · cited in 3 New Mexico opinions naming this issue, 1997–2011
2 sentences

1998See Scott v. AZL Resources, Inc., 107 N.M. 118, 121 , 753 P.2d 897, 900 (1988) (an essential element of the alter ego doctrine to pierce the corporate veil is proof of unity of interest and ownership); Garcia v. Coffman, 1997-NMCA-092, ¶ 15 , 124 N.M. 12 , 946 P.2d 216 (alter ego doctrine requisite to pierce corporate veil); Harlow v. Fibron Corp., 100 N.M. 379, 382 , 671 P.2d 40, 43 (Ct.App.1983) (same). {15} To argue that the exclusivity provisions do not apply to 6001, Inc., Plaintiff submitted her affidavit stating in part: Kenny Blume and Joe Reese were the highest ranking managers at the

1998See Scott v. AZL Resources, Inc., 107 N.M. 118, 121 , 753 P.2d 897, 900 (1988) (an essential element of the alter ego doctrine to pierce the corporate veil is proof of unity of interest and ownership); Garcia v. Coffman, 1997-NMCA-092, ¶ 15 , 124 N.M. 12 , 946 P.2d 216 (alter ego doctrine requisite to pierce corporate veil); Harlow v. Fibron Corp., 100 N.M. 379, 382 , 671 P.2d 40, 43 (Ct.App.1983) (same). {15} To argue that the exclusivity provisions do not apply to 6001, Inc., Plaintiff submitted her affidavit stating in part: Kenny Blume and Joe Reese were the highest ranking managers at the

23
Scott v. AZL Resources, Inc.green
nm · 1988 · cited in 3 New Mexico opinions naming this issue, 1997–2005
2 sentences

2005See, e.g., Jemez Agency, Inc. v. CIGNA Corp., 866 F.Supp. 1340, 1343-44 (D.N.M.1994) (requiring the plaintiffs to satisfy all three prongs of the alter ego test for liability as set forth in Scott, 107 N.M. at 121 , 753 P.2d at 900 ).

2005See, e.g., Jemez Agency, Inc. v. CIGNA Corp., 866 F.Supp. 1340, 1343-44 (D.N.M.1994) (requiring the plaintiffs to satisfy all three prongs of the alter ego test for liability as set forth in Scott, 107 N.M. at 121 , 753 P.2d at 900 ).

23
Cruttenden v. Manturagreen
nm · 1982 · cited in 2 New Mexico opinions naming this issue, 1983–2005
2 sentences

2005We have applied the alter ego exception to a question of the liability of a parent corporation for the acts of its subsidiaries in cases like Cruttenden v. Mantura, 97 N.M. 432, 434-35 , 640 P.2d 932, 934-35 (1982).

2005We have applied the alter ego exception to a question of the liability of a parent corporation for the acts of its subsidiaries in cases like Cruttenden v. Mantura, 97 N.M. 432, 434-35 , 640 P.2d 932, 934-35 (1982).

12
Oxley v. Southland Life Ins. Co.green
okla · 1932 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See Mahaney, 89 N.M. at 211 , 549 P.2d at 626 (stating that the 12 determination of alter ego describes situations where “the shareholders have so 13 manipulated the corporation to further their own individual interests that the identity 14 of the corporation has merged into its shareholders”); Harlow, 100 N.M. at 382 , 671 15 P.2d at 43 (stating that it must be proven that the “corporation was operated not in a 16 legitimate fashion to serve the valid goals and purposes of that corporation but that it 17 functioned under the domination and control and for the purposes of some dominant 18 part

11
Medina v. Four Winds International Corp.green
wyd · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir. 2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int’l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir.2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int'l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

11
ACE & Co., Inc. v. Balfour Beatty PLCgreen
ded · 2001 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir. 2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int’l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir.2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int'l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

11
Sonora Diamond Corp. v. Superior Courtgreen
calctapp · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005Ct., 83 Cal.App.4th 523 , 99 Cal.Rptr.2d 824, 835-37 (2000) (indicating that California requires two factors to be met before corporate veil may be pierced for jurisdictional purposes — (1) unity of interest and ownership and (2) inequitable result caused by wrongdoing or fraud); Flight Int'l Aviation Training Ctr., Inc. v. Rivera, 651 So.2d 1265, 1266 (Fla.Dist.Ct.App.1995) (holding that wrongful or improper purpose must be shown for jurisdictional purposes).

2005Ct., 83 Cal.App.4th 523 , 99 Cal.Rptr.2d 824, 835-37 (2000) (indicating that California requires two factors to be met before corporate veil may be pierced for jurisdictional purposes — (1) unity of interest and ownership and (2) inequitable result caused by wrongdoing or fraud); Flight Int'l Aviation Training Ctr., Inc. v. Rivera, 651 So.2d 1265, 1266 (Fla.Dist.Ct.App.1995) (holding that wrongful or improper purpose must be shown for jurisdictional purposes).

11
Jemez Agency, Inc. v. Cigna Corp.green
nmd · 1994 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., Jemez Agency, Inc. v. CIGNA Corp., 866 F.Supp. 1340, 1343-44 (D.N.M. 1994) (requiring the plaintiffs to satisfy all three prongs of the alter ego test for liability as set forth in Scott, 107 N.M. at 121 , 753 P.2d at 900 ).

2005See, e.g., Jemez Agency, Inc. v. CIGNA Corp., 866 F.Supp. 1340, 1343-44 (D.N.M.1994) (requiring the plaintiffs to satisfy all three prongs of the alter ego test for liability as set forth in Scott, 107 N.M. at 121 , 753 P.2d at 900 ).

11
cluster 770917green
ca7 · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir. 2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int’l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

2005States, Southeast and Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 940 (7th Cir.2000); ACE & Co. v. Balfour Beatty PLC, 148 F.Supp.2d 418, 425 (D.Del.2001) (holding that Delaware law requires fraud, injustice, or inequity to be shown before the alter ego doctrine can be used to find personal jurisdiction over a parent corporation); Medina v. Four Winds Int'l Corp., 111 F.Supp.2d 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super.

11
John Doe v. Unocal Corporationgreen
ca9 · 2001 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005Svcs., Inc. v. Bell & Clements Ltd., 328 F.3d 1122, 1134-35 (9th Cir.2003) (“To satisfy the alter ego exception to the general rule that a subsidiary and the parent are separate entities [for purposes of personal jurisdiction], the plaintiff must make out a prima facie case (1) that there is such unity of interest and ownership that the separate personalities [of the two entities] no longer exist and (2) that failure to disregard [their separate identities] would result in fraud or injustice.” (internal quotation marks and citations omitted)); Doe v. Unocal Corp., 248 F.3d 915, 926-28 (9th Cir

2005Svcs., Inc. v. Bell & Clements Ltd., 328 F.3d 1122, 1134-35 (9th Cir.2003) ("To satisfy the alter ego exception to the general rule that a subsidiary and the parent are separate entities [for purposes of personal jurisdiction], the plaintiff must make out a prima facie case (1) that there is such unity of interest and ownership that the separate personalities [of the two entities] no longer exist and (2) that failure to disregard [their separate identities] would result in fraud or injustice." (internal quotation marks and citations omitted)); Doe v. Unocal Corp., 248 F.3d 915, 926-28 (9th Cir

11
Harris Rutsky & Co. Insurance Services, Inc. v. Bell & Clements Limitedgreen
ca9 · 2003 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005Svcs., Inc. v. Bell & Clements Ltd., 328 F.3d 1122, 1134-35 (9th Cir.2003) (“To satisfy the alter ego exception to the general rule that a subsidiary and the parent are separate entities [for purposes of personal jurisdiction], the plaintiff must make out a prima facie case (1) that there is such unity of interest and ownership that the separate personalities [of the two entities] no longer exist and (2) that failure to disregard [their separate identities] would result in fraud or injustice.” (internal quotation marks and citations omitted)); Doe v. Unocal Corp., 248 F.3d 915, 926-28 (9th Cir

2005Svcs., Inc. v. Bell & Clements Ltd., 328 F.3d 1122, 1134-35 (9th Cir.2003) ("To satisfy the alter ego exception to the general rule that a subsidiary and the parent are separate entities [for purposes of personal jurisdiction], the plaintiff must make out a prima facie case (1) that there is such unity of interest and ownership that the separate personalities [of the two entities] no longer exist and (2) that failure to disregard [their separate identities] would result in fraud or injustice." (internal quotation marks and citations omitted)); Doe v. Unocal Corp., 248 F.3d 915, 926-28 (9th Cir

11
Northern Laminate Sales, Inc. v. Matthewsgreen
nhd · 2003 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See id.; see also N. Laminate Sales, Inc. v. Matthews, 249 F.Supp.2d 130, 137 (D.N.H.2003) (applying a traditional alter-ego test to the question, and discussing the use of an alter-ego theory to pierce the corporate veil to establish jurisdiction so that corporate contacts may be attributed to another); Snell v. Bob Fisher Enters., Inc., 106 F.Supp.2d 87, 90 (D.Me.2000) (same).

2005See id.; see also N. Laminate Sales, Inc. v. Matthews, 249 F.Supp.2d 130, 137 (D.N.H.2003) (applying a traditional alter-ego test to the question, and discussing the use of an alter-ego theory to pierce the corporate veil to establish jurisdiction so that corporate contacts may be attributed *593 to another); Snell v. Bob Fisher Enters., Inc., 106 F.Supp.2d 87, 90 (D.Me.2000) (same).

11
Purple Onion Foods, Inc. v. Blue Moose of Boulder, Inc.green
nmd · 1999 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005The result of satisfying the alter ego test when applied to jurisdiction would be to “attribut[e] [the] contacts of one person or entity to another.” Purple Onion Foods, Inc. v. Blue Moose of Boulder, Inc., 45 F.Supp.2d 1255, 1258 (D.N.M.1999).

2005The result of satisfying the alter ego test when applied to jurisdiction would be to "attribut[e] [the] contacts of one person or entity to another." Purple Onion Foods, Inc. v. Blue Moose of Boulder, Inc., 45 F.Supp.2d 1255, 1258 (D.N.M.1999).

11
Snell v. Bob Fisher Enterprises, Inc.green
med · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See id.; see also N. Laminate Sales, Inc. v. Matthews, 249 F.Supp.2d 130, 137 (D.N.H.2003) (applying a traditional alter-ego test to the question, and discussing the use of an alter-ego theory to pierce the corporate veil to establish jurisdiction so that corporate contacts may be attributed to another); Snell v. Bob Fisher Enters., Inc., 106 F.Supp.2d 87, 90 (D.Me.2000) (same).

2005See id.; see also N. Laminate Sales, Inc. v. Matthews, 249 F.Supp.2d 130, 137 (D.N.H.2003) (applying a traditional alter-ego test to the question, and discussing the use of an alter-ego theory to pierce the corporate veil to establish jurisdiction so that corporate contacts may be attributed *593 to another); Snell v. Bob Fisher Enters., Inc., 106 F.Supp.2d 87, 90 (D.Me.2000) (same).

11
FLIGHT AVIATION TRAINING v. Riveragreen
fladistctapp · 1995 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005Ct., 83 Cal.App.4th 523 , 99 Cal.Rptr.2d 824, 835-37 (2000) (indicating that California requires two factors to be met before corporate veil may be pierced for jurisdictional purposes — (1) unity of interest and ownership and (2) inequitable result caused by wrongdoing or fraud); Flight Int’l Aviation Training Ctr., Inc. v. Rivera, 651 So.2d 1265, 1266 (Fla.Dist.Ct.App.1995) (holding that wrongful or improper purpose must be shown for jurisdictional purposes).

2005Ct., 83 Cal.App.4th 523 , 99 Cal.Rptr.2d 824, 835-37 (2000) (indicating that California requires two factors to be met before corporate veil may be pierced for jurisdictional purposes — (1) unity of interest and ownership and (2) inequitable result caused by wrongdoing or fraud); Flight Int'l Aviation Training Ctr., Inc. v. Rivera, 651 So.2d 1265, 1266 (Fla.Dist.Ct.App.1995) (holding that wrongful or improper purpose must be shown for jurisdictional purposes).

11
Southern Union Exploration Co. v. Wynn Exploration Co.green
nmctapp · 1981 · cited in 1 New Mexico opinions naming this issue, 1997–1997
2 sentences

1997See Southern Union Exploration Co. v. Wynn Exploration Co., 95 N.M. 594, 600 , 624 P.2d 536, 542 (Ct.App.1981).

1997See Southern Union Exploration Co. v. Wynn Exploration Co., 95 N.M. 594, 600 , 624 P.2d 536, 542 (Ct.App.1981).

11
SOUTHERN UNION, ETC. v. Wynn Explorationgreen
nmctapp · 1981 · cited in 1 New Mexico opinions naming this issue, 1997–1997
2 sentences

1997See Southern Union Exploration Co. v. Wynn Exploration Co., 95 N.M. 594, 600 , 624 P.2d 536, 542 (Ct.App.1981).

1997See Southern Union Exploration Co. v. Wynn Exploration Co., 95 N.M. 594, 600 , 624 P.2d 536, 542 (Ct.App.1981).

11
Carson Meadows Incorporated v. Peasegreen
nev · 1975 · cited in 1 New Mexico opinions naming this issue, 1976–1976
1 sentence

1976The Supreme Court of Nevada in Carson Meadows Incorporated v. Pease, 533 P.2d 458, 460 (Nev.1975) stated it this way: “The alter ego doctrine may be applied when the corporation is influenced and governed by the person or persons asserted to be its alter ego [where] ; there is such unity of interest and ownership that one is inseparable from the other; and adherence to the fiction of separate entity would sanction a fraud or promote injustice.” In finding alter ego, the trial court stated that “defendants manipulated the corporate entity to their own purpose, convenience and benefit.” The appe

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Memorial Medical Center, Inc. v. Tatsch Construction, Inc. green
nm · 2000
2 sentences

2025Ctr., Inc. v. Tatsch Constr., Inc., 2000-NMSC-030 , 129 N.M. 677 , 12 P.3d 431 . [MIO 2-13] However, we find no indication that Plaintiff advanced this argument below.

2025Ctr., Inc. v. Tatsch Constr., Inc., 2000-NMSC-030 , 129 N.M. 677 , 12 P.3d 431 . [MIO 2-13] However, we find no indication that Plaintiff advanced this argument below.

12025–2025
Aeda v. Aeda green
nmctapp · 2013
1 sentence

2025“Unless a statute violates the Constitution, we will not question the wisdom, policy, or justness of legislation enacted by our Legislature.” Aeda v. Aeda, 2013-NMCA-095, ¶ 11 , 310 P.3d 646 (alteration, internal quotation marks, and citation omitted). {22} In closing, we acknowledge Plaintiff’s most recent argument, that a different result might properly be reached in this matter by applying the alter ego analysis set forth in Mem’l Med.

12025–2025
Energy Reserves Group, Inc. v. Superior Oil Co. green
ksd · 1978
2 sentences

2005Furthermore, “[t]o read Cannon or the alter ego doctrine as a limitation upon International Shoe Co. is to elevate to a constitutional level a statutory obstacle to extraterritorial service of process that was generated in the context of a now obsolete jurisdictional analysis.” Energy Reserves, 460 F.Supp. at 504 .

2005Furthermore, "[t]o read Cannon or the alter ego doctrine as a limitation upon International Shoe Co. is to elevate to a constitutional level a statutory obstacle to extraterritorial service of process that was generated in the context of a now obsolete jurisdictional analysis." Energy Reserves, 460 F.Supp. at 504 .

12005–2005
Garcia v. Coffman green
nmctapp · 1997
2 sentences

1998See Scott v. AZL Resources, Inc., 107 N.M. 118, 121 , 753 P.2d 897, 900 (1988) (an essential element of the alter ego doctrine to pierce the corporate veil is proof of unity of interest and ownership); Garcia v. Coffman, 1997-NMCA-092, ¶ 15 , 124 N.M. 12 , 946 P.2d 216 (alter ego doctrine requisite to pierce corporate veil); Harlow v. Fibron Corp., 100 N.M. 379, 382 , 671 P.2d 40, 43 (Ct.App.1983) (same). {15} To argue that the exclusivity provisions do not apply to 6001, Inc., Plaintiff submitted her affidavit stating in part: Kenny Blume and Joe Reese were the highest ranking managers at the

1998See Scott v. AZL Resources, Inc., 107 N.M. 118, 121 , 753 P.2d 897, 900 (1988) (an essential element of the alter ego doctrine to pierce the corporate veil is proof of unity of interest and ownership); Garcia v. Coffman, 1997-NMCA-092, ¶ 15 , 124 N.M. 12 , 946 P.2d 216 (alter ego doctrine requisite to pierce corporate veil); Harlow v. Fibron Corp., 100 N.M. 379, 382 , 671 P.2d 40, 43 (Ct.App.1983) (same). {15} To argue that the exclusivity provisions do not apply to 6001, Inc., Plaintiff submitted her affidavit stating in part: Kenny Blume and Joe Reese were the highest ranking managers at the

11998–1998

Where else courts name it

CA 235 (1941–2026) TX 109 (1966–2026) LA 46 (1963–2024) GA 30 (1975–2026) NV 28 (1957–2024) IL 21 (1980–2024) UT 18 (1985–2026) CO 17 (1966–2020) OH 17 (1992–2022) NY 11 (1987–2024) KS 11 (1972–2025) FL 10 (1968–2019) ND 8 (2008–2023) PA 7 (2010–2021) NM 7 (1976–2025) WA 6 (1939–2024) IA 6 (1971–2024) KY 5 (2012–2025) TN 5 (2002–2022) DE 5 (2006–2024) CT 5 (1999–2022) AZ 5 (1989–2021) AK 4 (2002–2025) MO 4 (1994–2020) SC 4 (2004–2025) NC 4 (1939–2017) ID 4 (1979–2023) MI 3 (2008–2017) MD 3 (1987–1989) HI 3 (2003–2024) NJ 3 (1996–2021) IN 3 (2012–2019) VT 3 (1996–2001) OR 2 (1988–2020) WV 2 (1999–2015) MN 2 (1992–2010) WY 2 (2019–2021) MS 2 (2012–2014) OK 2 (2023–2023) VI 2 (2023–2023) WI 2 (1996–2023) NE 2 (1993–2002)

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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