Taylor-Rush

Plaintiff/appellant Cheryl Taylor-Rush appeals an order quashing service of summons on six nonresident corporate officers and directors in her action against them and a nonresident corporation for breach of contract, fraud, conspiracy to defraud and other alleged wrongs. At issue is the applicability of the so-called “fiduciary shield doctrine.”

Facts

Appellant’s complaint charged respondents with breach of contract, fraud, breach of a written employment contract, breach of an agreement to convey stock, conspiracy to defraud, conspiracy to induce a breach of contract, and fraudulent transfer of securities. Although her complaint alleged that at all times the individual respondents were acting within the course and scope of their agency and employment by an out-of-state corporation, appellant sought jurisdiction over each respondent based on their individual tortious conduct toward her.

.. Respondents appeared specially and moved to quash service on the grounds they were protected by the “fiduciary shield doctrine”—that their activities within California and any other contacts with California in relation to appellant’s complaint were in performance of their duties as…