Ene v. Graham

Summary

The court held that the alter ego analysis for a limited liability company is the same as the analysis applied to a corporation, requiring findings on control, unity of interest and ownership, and fraud or injustice. It concluded that substantial evidence did not support the district court's findings on unity of interest or injustice, particularly because the court made no finding connecting Ene's conduct to Graham's injury. The court therefore reversed the alter ego determination and remanded, holding that Ene was not personally liable for IPH's negligence.