2003 • Volume 28 • Number 2

C.F. Trust, Inc. v. First Flight Limited Partnership: Will the Virginia Supreme Court Permit Outsider Reverse Veil-Piercing against a Limited Partnership?

Leslie C. Heilman

This comment analyzes the Fourth Circuit’s opinion in C.F. Trust, Inc. v. First Flight Limited Partnership. In particular, the author discusses whether the Virginia Supreme Court will recognize the doctrine of outsider reverse veil-piercing in the commercial context and apply it to a limited partnership. The author reviews and evaluates the characteristics of traditional veil-piercing and outsider reverse veil-piercing, as well as Virginia common law and the Virginia Revised Uniform Limited Partnership Act. Noting that Virginia law recognizes the doctrine of outsider reverse veil-piercing and will apply the doctrine under exceptional circumstances, the author concludes that the specific facts involved in C.F. Trust, Inc. call for the equitable remedy to be utilized by the Virginia Supreme Court.