Curley v. Dahlgren Chrysler-Plymouth Dodge, Inc.

In this appeal involving a closely held corporation, we consider whether the trial court properly dismissed (1) a claim of unlawful distribution of corporate assets because it was filed against shareholders rather than against duly elected directors and (2) a claim to impose shareholder liability for corporate debts as barred by the statute of limitations.

In 1987, Edward R. Curley, Jr., John Harry Hadjy, and Thalia Stevenson incorporated Dahlgren Chrysler-Plymouth, Dodge, Inc. (the dealership) and through it purchased an automobile dealer franchise. Chrysler Credit Corporation (Chrysler…