Also, as an amicus brief filed by corporate law scholars persuasively argues, granting the religious exemption to the owners would mean allowing shareholders to pass their religious values to the corporation. The fundamental principle of corporate law is a corporation’s existence as a legal entity with rights and obligations separate from those of its shareholders.
Dealing with this case has turned into a massive game of whack-a-mole. It'd be nice to have had more help. My arm's getting tired. But here goes one more whack, from my article A Critique of the Corporate Law Professors’ Amicus Brief in Hobby Lobby and Conestoga Wood, which is now available in final firm at the the Virginia Law Review Online:
The Brief’s central argument rests on the corporation’s status as a legal entity separate from its shareholders. According to the Brief, “[t]he centrality of corporate ‘separateness’ is well-established in the United States.” “Indeed,” the Brief asserts, “this legal separateness—sometimes called legal ‘personhood’—has been the very basis of corporate law at least since the 18th Century.” All of which is true, but hardly dispositive of the issues in this case.
After all, it long also has been the law that “[t]he corporate form may be set aside … ‘as a means of preventing injustice or inequitable consequences.’” As far back as 1905, for example, a federal appellate court held that:
If any general rule can be laid down, in the present state of authority, it is that a corporation will be looked upon as a legal entity as a general rule, and until sufficient reason to the contrary appears; but, when the notion of legal entity is used to defeat public convenience, justify wrong, protect fraud, or defend crime, the law will regard the corporation as an association of persons.
In so holding, the court cited numerous precedents for the proposition that the corporation’s separate legal personality is neither absolute nor inviolate:
‘The abstract idea of a corporation, the legal entity, the impalpable and intangible creation of human thought, is itself a fiction, and has been appropriately described as a figure of speech. It serves very well to designate in our minds the collective action and agency of many individuals as permitted by the law; and the substantial inquiry always is what in a given case has been that collective action and agency?’ People v. North River Sugar Refining Co., 121 N.Y. 582, 621, 24 N.E. 834, 9 L.R.A. 33, 18 Am.St.Rep. 843. … ‘Corporations are but associations of individuals. ‘ Hightower v. Thornton, 8 Ga. 492, 52 Am.Dec. 412; 1 Kyd on Corp. 13. ‘Who, in law, constitute the company, if it be not the stockholders?’ Gelpcke v. Blake, 19 Iowa, 268. ‘A private corporation is, in fact, but an association of individuals united for a lawful purpose and permitted to use a common name in their business, and to have a change of members in their business.’ Field, J., in Kansas Pacific v. Atchison Railroad, 112 U.S. 414, 5 Sup.Ct. 208, 28 L.Ed. 794.
The law thus has long recognized William Klein’s point that, despite the utility of the fiction of corporate legal personhood, it is critical to remember that treating the corporation as an entity separate from the people making it up bears no relation to economic reality. In appropriate cases, courts will set aside the corporation’s separate legal personhood and view the corporation as the aggregate of its shareholders.
 Brief, supra note 12, at 4.
 Id. at 5.
 Co-Ex Plastics, Inc. v. AlaPak, Inc., 536 So.2d 37, 38 (Ala.1988) (citation omitted).
 U.S. v. Milwaukee Refrigerator Transit Co., 142 F. 247, 255 (7th Cir. 1905). For other early cases in which the corporate veil was pierced and the corporation’s separate legal personhood disregarded, see Hinkley v. Reed, 82 Ill.App. 60 (1899) (“The court will sometimes ignore the corporate existence in order to do justice.”); Cheeney v. Ocean S.S. Co., 92 Ga. 726 (1893) (discussing alter-ego theory for disregarding corporate form).
 Id. at 254-55
 See generally William A. Klein, Business Organization and Finance 97-106 (1st ed. 1980) (criticizing reification of the corporation; see also G. Mitu Gulati et al., Connected Contracts, 47 UCLA L. Rev. 887, 891 (2000) (noting that “it is dangerous to ignore the reality that firms transact only through individuals”).