California Corporation Owe No Fiduciary Duties to their Creditors

In an issue of first impression in California, the California Court of Appeal, Sixth Appellate District found that a corporation's officers and directors owed no fiduciary duties to the corporation's creditors, even if the corporation is in "zone of insolvency".  This seems a sensible result, as the courts should not dilute those duties owed to the corporation itself and its shareholders.  This is especially so in the "loan to own" world where the creditor is interested in using its creditor status to remove the board and put itself in the place of the shareholder.