As you know, the shareholder primacy theory is widely attributed to the Chicago school of economists, beginning in the 1970s, with economist Milton Friedman famously arguing that the only "social responsibility of business is to increase its profits."
Here's another earnings management case from SEC Enforcement, this time against Roadrunner Transportation Systems, Inc., a shipping and logistics company formerly traded on the NYSE, involving a veritable pu pu platter of alleged financial manipulations.
As applied in Delaware—where it is applied most often—the doctrine, she argues, is "on a collision course with the legitimate regulatory interests of other states (and indeed the federal government)."