Minton v. Cavaney

In Minton v. Cavaney (1961) 56 Cal.2d 576, the plaintiff judgment creditors had previously recovered damages against a corporation for the wrongful death of their daughter. (Id. at p. 578.) Unable to satisfy the judgment, the judgment creditors sued the then-defunct corporation's alter ego seeking to enforce against the alter ego the judgment that had previously been entered against the corporation. The Court refused to enforce against the alter ego the earlier judgment because the plaintiffs "did not allege or present any evidence on the issue of the corporation's negligence or on the amount of damages sustained by plaintiffs. They relied solely on the judgment against the corporation." (Id. at p. 581.) The Court agreed that the alter ego could not "be held liable for the debts of the corporation without an opportunity to relitigate these issues." (Ibid.)