context: But each case will turn on its specific facts. Particularly in the context of small, closely held corporations, a corporate insider may stand to lose more than an outside creditor from a majority shareholder's fraudulent abuse of the corporation's limited liability.
citation_a.signal: cf.
citation_a.parenthetical: recognizing special dangers and creating protections under Massachusetts common law for minority shareholders in closely held corporation
citation_a.sentence: Cf. Donahue v. Rodd Electrotype Co., 367 Mass. 578, 328 N.E.2d 505, 514-16 (1975) (recognizing special dangers and creating protections under Massachusetts common law for minority shareholders in closely held corporation); but see Nixon v. Blackwell, 626 A.2d 1366, 1379-81 (Del.1993) (declining to judicially create parallel rule under Delaware common law).
citation_b.signal: but see
citation_b.identifier: 626 A.2d 1366, 1379-81
citation_b.parenthetical: declining to judicially create parallel rule under Delaware common law
citation_b.sentence: Cf. Donahue v. Rodd Electrotype Co., 367 Mass. 578, 328 N.E.2d 505, 514-16 (1975) (recognizing special dangers and creating protections under Massachusetts common law for minority shareholders in closely held corporation); but see Nixon v. Blackwell, 626 A.2d 1366, 1379-81 (Del.1993) (declining to judicially create parallel rule under Delaware common law).