In Fletcher v. Havre de Grace Fireworks Co., 229 Md. 196, 177 A.2d 908 (1962), a fireworks plant exploded. The explosion and resulting fire injured the plaintiff and damaged her home. She sued the fireworks plant, as well as its officers and directors individually. The plaintiff's theory against the individual directors was that they were liable because they controlled the conduct of the business. The lower court sustained demurrers by the individual officers on the grounds that the plaintiff's allegations were "too general to charge the directors with liability." Id. at 199. The Court of Appeals affirmed this judgment, explaining: It is manifest, we think, that the allegation in the trespass q.c.f. count that the officer- director defendants had and exercised "complete direction and control over all phases of the conduct of the business of the defendant company," and the more comprehensive allegation of similar import in the negligence, extra-hazardous and nuisance counts, fall far short of alleging that the individual defendants had personally directed or actively participated or cooperated in the tort committed by the corporation. Id. at 201.