St. John's Law Review

The Changing Standards by Which Directors will be Judged

By: Harvey L. Pitt

For at least a century, the role of non-management corporate directors was often treated as one of passivity, not activism. Power to manage a corporation’s affairs was believed to reside exclusively in the hands of its senior officers, with the proper role of outside directors being generically and non-intrusively to oversee, and approve (when asked to do so), significant managerial decisions.

Corporate scandals bred in the ‘90s exposed this weak leadership, which at times had permitted practices that were clearly illegal to occur and thrive nonetheless.  The passage of the Sarbanes-Oxley Act (“S-Ox”) in July, 2002 reemphasized the role of directors as elected representatives of the shareholders and the stewards of company assets.

The liability landscape for corporate directors has been changing dramatically.  Most recently, three events are causing greater focus by directors on the thorny issue of personal liability:  (1) The Emerging Communications case, decided by the Delaware Chancery Court last June; (2) the Disney shareholders’ suit over former President Michael Ovitz’s $140 million severance package; and (3) the recent proposed settlements, by outside directors, of WorldCom and Enron class action litigation last month.  The outcomes of these three phenomena suggest the need for outside directors to adopt a proactive stance in performing their oversight functions.

Traditionally, corporations shield individuals from personal liability except in egregious circumstances.  This is why corporations are separate legal entities.  As a separate “person,” the corporation is generally responsible for the firm’s actions.  This is so because corporations are expected to take appropriate business risks.  If personal liability extended to managers and directors, they would take far fewer risks.  That would mean fewer corporations, fewer investments, and fewer jobs.  Managers and directors would not be inclined to pursue transactions where the costs exceeded the benefits to themselves, the wrong measure for any corporate decision.  Therefore, from a policy perspective, corporate law traditionally has embraced the view that it is better to encourage directors and managers to take risks, so corporations can create wealth and jobs.  In the end, the threat of personal liability might make directors and managers excessively risk averse in their decision-making, thereby injuring shareholders, chilling investment, and diminishing efficiency.