Brief English Introduction
The First Circuit treated veil piercing as an evidence problem as much as a doctrine problem. Creditors often face an information disadvantage, so burden-shifting may be appropriate once their evidence creates reasonable suspicion of abuse; weak evidence of personnel or property overlap, however, is not enough.
Use It For
Use this case to make students specify what evidence proves commingling and what evidence merely raises suspicion.
Teaching Notes
The case is helpful for litigation design. Ask students to build two files: one for the creditor trying to trigger burden-shifting, and one for the shareholder trying to show independent accounts, assets, decisions, and operations.