This is a legal myth:

> The case still most often used in law schools to illustrate a director’s obligation is Dodge v. Ford Motor (1919)—even though an important 2008 paper by Lynn A. Stout explains that it’s bad law, now largely ignored by the courts. It has been cited in only one decision by Delaware courts in the past 30 years.

* https://hbr.org/2010/04/the-myth-of-shareholder-capitalism

The Stout paper, "Why We Should Stop Teaching Dodge v. Ford":

> This Essay argues that Dodge v. Fordis indeed bad law, at least when cited for the proposition that the corporate purpose is, or should be, maximizing shareholder wealth. Dodge v. Ford is a mistake, a judicial "sport," a doctrinal oddity largely irrelevant to corporate law and corporate practice. What is more, courts and legislatures alike treat it as irrelevant. In the past thirty years, the Delaware courts have cited Dodge v. Ford as authorint in only one unpublished case, and then not on the subject of corporate purpose, but on another legal question entirely.15

* https://scholarship.law.cornell.edu/facpub/724/