Salgo v. Matthews
Court of Civil Appeals of Texas
497 S.W.2d 620 (1973)
At General Electrodynamics Corporation's annual meeting, chaired by Salgo (defendant) with Meer serving as election inspector, Matthews and Thorp (plaintiffs) presented Meer with documents purporting to give them proxy authority to vote shares held by Pioneer Casualty Company, a shareholder then in receivership, tracing through a chain of proxies from the court-appointed receiver McFarling to a Shepherd who was in bankruptcy. Meer refused to accept the proxies, and Matthews and Thorp immediately sued for an order requiring Salgo and Meer (defendants) to accept the proxies, count the votes, and declare their preferred candidates elected; the trial court granted that injunctive relief.
Whether a court may grant injunctive relief requiring an election inspector to accept proxies at a shareholders' meeting, where the parties challenging the decision are not seeking relief in a quo warranto proceeding following the election.