In Wilkes v. Springside Nursing Home, Inc., 370 Mass. 842, 353 N.E.2d 657 (Mass. 1976), the Massachusetts Supreme Judicial Court affirmed that majority shareholders in a close corporation owe a fiduciary duty to the minority, but asserted that the majority had "certain rights to what has been termed 'self ownership.'" 353 N.E.2d at 663. The court applied a strict fiduciary standard to the majority's actions, but observed that such a strict standard might discourage controlling shareholders from taking legitimate actions in fear of being held in violation of a fiduciary duty. Id. In light of this observation, the court adopted a balancing test. Id. This test weighed the majority's right of self-interest against the fiduciary duty owed to the minority considering the following factors: (1) whether the majority could demonstrate a legitimate business purpose for its action; (2) whether the minority had been denied its justifiable expectations by the majority's actions; (3) whether an alternative course of action was less harmful to the minority's interests. Id. at 663-64. Using this approach, the Wilkes court found that the proper method would be to place the initial burden on the majority shareholder to demonstrate a legitimate business purpose for the actions taken. Id. After such a showing the burden would shift to the minority to show that the same legitimate objective could have been achieved through an alternative course of action less harmful to the minority's interests. Id.