Minton v. Cavaney
Supreme Court of California
364 P.2d 473 (1961)
Seminole Hot Springs Corporation (Seminole) operated a swimming pool but had no assets besides its leased facility, which it ultimately lost for nonpayment of rent; Cavaney (defendant) served as Seminole's director, secretary, and treasurer even though Seminole never actually issued stock (though it once proposed to give him one of three shares), and Seminole's records were kept, and its mail sometimes received, at Cavaney's own office. After the plaintiffs' daughter drowned in Seminole's pool, they won an unsatisfied $10,000 judgment against Seminole and then sued Cavaney personally; the trial court found for the plaintiffs, and Cavaney appealed.
Whether an owner of a corporation may be held liable for corporate debts if he actively participated in the business and the business was undercapitalized.