no New Mexico case has ever said that. It is true that Cruttenden addressed only instrumentality. 97 N.M. at 434-35, 640 P.2d at 934-35. But that case found no instrumentality and therefore “did not reach the question of improper purpose.” Harlow, 100 N.M. at 382, 671 P.2d at 43. Cases are not authority for propositions not 1164, 1168-69 (D.Wyo.2000) (same under Wyoming law); Sonora Diamond Corp. v. Super. Ct., 83 Cal.App.4th 523, 99 Cal.Rptr.2d 824, 835-37 (2000) (indicating that California requires two factors to be met before corporate veil may be pierced for jurisdictional purposes — (1) unity of interest and ownership and (2) inequitable result caused by wrongdoing or fraud); Flight Int’l Aviation Training Ctr., Inc. v. Rivera, 651 So.2d 1265, 1266 (Fla.Dist.Ct.App.1995) (<HOLDING>). The reason for this rule is that corporations
holding that prejudice must be shown from an ex parte communication holding that the end of a conspiracy must be affirmatively shown holding that special damages must be shown to be reasonable and necessarily resulting from accident holding  2513 to be jurisdictional and therefore must be strictly construed holding that wrongful or improper purpose must be shown for jurisdictional purposes