CORPORATIONS - EQUITABLE INTERVENTION IN CORPORATE AFFAIRS - MEANING OF "INTERNAL MANAGEMENT''

In a recent case before the Court of Appeals of Maryland, Williams v. Salisbury Ice Co., a minority stockholder who had met with defeat in a prior struggle over the control of the defendant, a domestic corporation, filed a bill of complaint asking for the appointment of a receiver to manage the corporation until the rights of creditors and stockholders could be "permanently preserved." It appeared that one Meeker, who was the virtual owner of a competing ice company, had acquired ownership of a majority of the defendant corporation's stock. The defendant was solvent, but the plaintiff's chief source of complaint was that the defendant's retail ice business had been sold to the competing company at a grossly inadequate price. The evidence did not support this contention and the upper court affirmed the circuit court's decree dismissing the bill.