A year ago, I wrote this post discussing the Court of Appeal’s decision in Wolf v. CDS Devco, 185 Cal.App.4th 903 (2010). In that case, a director was removed shortly after filing an inspection demand pursuant to Corporations Code Section 1602. Before removal, the director inadvertently sent the corporation a copy of his complaint to enforce his inspection rights. The Fourth District Court of Appeal concluded that the director lost standing to demand inspection upon his removal.

In Wolf, the court observed that a director could be denied the right to inspect corporate documents based on the director’s “potential adversary status to [the corporation],” as illustrated by the inspection request.