In this article, Professors Thompson and Smith argue for an alternative to the judge-centered solutions that courts have adopted to address the problem of shareholders who cannot exercise control over corporate managers.  They argue for a “sacred space” approach which demands rules of corporate governance that carve out a specific set of decisions that shareholders make alone, without managerial control.  With the increasing number of active institutional investors as shareholders, Thompson and Smith’s approach provides a clearer way to address shareholder-director conflicts and current takeover controversies and acknowledges contemporary changes in shareholder consensus.