Consumer's Co-op v. Olsen
Wisconsin Supreme Court
419 N.W.2d 211 (1988)
Chris Olsen founded ECO with roughly $7,000 in initial capital, holding it and his parents' shares while the family met informally but rarely held formal board meetings, always conducted business in ECO's name, and never commingled funds; ECO's finances deteriorated to a $150,000 negative shareholder equity by 1983, yet Consumer's Co-op (plaintiff) continued extending credit to ECO for months past its own 60-day delinquency policy before finally cutting ECO off. Consumer's Co-op sued the Olsens (defendants) to pierce ECO's corporate veil, and the trial court found for Consumer's Co-op based on undercapitalization and Chris Olsen's control.
Whether undercapitalization alone can constitute grounds for piercing the corporate veil.