Commentators Sparks and Hamermesh, in a 1992 article, suggested a somewhat limited applicability to officers:   While there are no cases directly on point, the concept of an officer as the repository of delegated management authority by the board suggests that the availability of a business judgment rule defense may only be available to a corporate officer when that officer is operating within the scope of the delegated authority …  As a result, officers face a dual… [read post]