Poyner v. Lear Siegler, Inc.’s Empirical Analysis
542 F.2d 955 · 1976
Citation profile
11 federal appellate · 1 district · 7 state decisions
How this case has been cited
Cited by 31 later decisions — most recently August 2012 · most notably Boggs v. Blue Diamond Coal Co. (1979), Poyner v. Erma Werke Gmbh (1980)
11 federal appellate · 1 district · 7 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Erie Co v. Tompkins · Galena Oaks Corporation v. Frank Scofield, Collector of Internal Revenue · Minton v. Cavaney · Campbell Soup Co. v. Lojeski · American Railway Express Company v. Commonwealth
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Whether it is appropriate to disregard the corporate entity, and whether Poy-ner would have to litigate both liability for the injuries and LSI’s liability for Erma’s obligations in order to recover from LSI, are clearly questions of law. Whether an arrangement works an “unfair” hardship is similarly a question of law. If a determination concerns whether the evidence showed that something occurred or existed, it is a finding of fact. However, if a determination is made by processes of legal reasoning from, or of interpretation of the legal significance of, the evidentiary facts, it is a conclusion of law. Galena Oaks Corp. v. Scofield, 218 F.2d 217, 219 (5th Cir.1954). See also Kippen v. Am. Automatic Typewriter Co., 324 F.2d 742, 745 (9th Cir.1963) (whether there was “good cause” to discharge); Campbell Soup Co. v. Wentz, 172 F.2d 80 (3rd Cir.1948) (whether carrots are “unique,” permitting the remedy of specific performance). The issue whether a corporate arrangement works a hardship which is “unfair,” and which therefore warrants denial of corporate entity treatment, is a question about the legal consequences which follow from the arrangement. It is therefore a conclusion of law.”
1 later decision quote this exact passage · from the majority“The approach of the Kentucky courts to piercing the corporate veil has been described as evincing “a general aversion for any disregard of the corporate entity.” Campbell, “Limited Liability for Corporate Shareholders: Myth or Matter-of-Fact,” 63 Ky.L.J. 23, 48 (1975). Poy-ner argues that we should expand the doctrine of Minton v. Cavaney, 56 Cal.2d 576 , 15 Cal.Rptr. 641 , 364 P.2d 473 (1961), which provides that the corporate veil should be pierced if a corporation is grossly undercapitalized, see 1 Fletcher, Cyclopedia of the Law of Private Corporations § 44.1 (1974), and apply it to this case because LSI “has refused to risk any of its subsidiaries’ assets in this country.” But Poyner has cited no cases, and we have found none, in which the Kentucky courts have followed the growing trend of denying corporate entity treatment for inadequate capitalization, except in the event of fraudulent reorganization. E. g., Harlan Pub. Svce. Co. v. Eastern Constr. Co., 254 Ky. 135 , 71 S.W.2d 24, 29 (1934). We do not believe that the Kentucky courts would so extend a doctrine which they have not yet adopted in its basic formulation.”
1 later decision quote this exact passage · from the majority“Before a Kentucky court will disregard the corporate entity, it must also determine that the artificial personality serves to shield individuals from legal responsibility for fraudulent or criminal acts, or that the form of organization is subversive of public policy.” 542 F.2d at 958 (citations omitted). . Many commentators share Judge Martin’s view in White, 584 S.W.2d at 61 , that the instrumentality and alter ego tests are essentially interchangeable.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.