Rowland v. LePire, 99 Nev. 308,662 P.2d 1332 (1983) |
In this case, the Rowland Corporation contracted to build a house for Eugene and Judy Lepire. Following problems on the project, the Lepires filed a breach of contract suit against the Rowland Corporation, which also counter claimed for breach of contract. The total capitalization of the corporation was $1,100. No formal directors or shareholders meetings were ever held, no dividends were ever paid, and neither the officers nor directors were paid. Also, the corporation had no minute book. However, it did have a contractor's license and a corporate checking account. It also obtained workers' compensation insurance and transacted business with the state Employment Security Division.
The Lepires won at trial, and the trial court awarded them $65,000. Further, the court found that the Rowland Corporation was the alter ego of Glen Rowland and Martin Rowland and entered a personal judgment against them. The judgment was then appealed:
The Nevada Supreme court reversed the personal judgment. The court concluded that the corporation was, indeed, undercapitalized and that there was little existence separate and apart from Martin and Glen Rowland. Yet, the court failed to "pierce the corporate veil.