The West Virginia Constitution provides for corporations in Article XI, and states the traditional understanding related to liability:
11-2. Corporate liability for indebtedness.
The stockholders of all corporations and joint-stock companies, except banks and banking institutions, created by laws of this state, shall be liable for the indebtedness of such corporations to the amount of their stock subscribed and unpaid, and no more.
So, suppose that one seeks to pierce the corporate veil. Does this provision allow for that? Typically, common law allowed veil piercing and constitutions often provide that something that existed in common law remains (which appears to be the case here). I guess, then, veil piercing is okay, though I think one could argue that a constitutional basis for limited liability should be stronger than a statutory one.
The better argument, I think, is that veil piercing disregards the entity. Thus, the constitutional protection does not connect, because there is no corporation. If we thought of things this way, we'd probably be more reluctant to veil pierce, because it would be a judicial statement that the corporation that was purportedly formed does not exist because of the failures of those in charge of the entity.
Where the shareholders truly don't intend to have an entity, I am okay with this, but that's really the rarity. Where there is fraud, prove fraud. Where there is a constitutional protection for limited liability, the respect for the entity should be exceedingly strong. Stronger than the common law standard.
I am not arguing that a constitutional right to limited liability is a good idea — I'm currently agnostic on that. I'm questioning whether constitutional corporate status changing the veil piercing calculation. I am thinking yes, but I am not sure to what degree. I plan to give this some more thought, but I welcome comments on how constitutional limited liability status (once it exists) should change veil piercing analysis.