Jones v. H.F. Ahmanson & Co

In Jones v. H.F. Ahmanson & Co. (1969) 1 Cal.3d 93, the California Supreme Court recognized an exception to the requirement that a shareholder must bring a derivative action in the name of the corporation. It held that if a minority stockholder was bringing suit against the majority stockholders for breach of fiduciary duty owed by the majority stockholders to the minority stockholders, then "an individual cause of action exists" because the injury was "not incidental to an injury to the corporation." ( Jones v. H.F. Ahmanson & Co., supra, 1 Cal.3d at p. 107.)