It was a 1990 "Harvard Business Review" article, "CEO Incentives: It's Not How Much You Pay, But How" by Jensen and Kevin J. Murphy, that prescribed executive stock options to maximize shareholder value. The justification they gave was that shareholders were the "residual claimants" of the corporation so they had the sole right to profits. The idea that shareholders are the sole residual claimants was later challenged by legal scholars, and some (such as Stout 2002) actively reject it, in favor of other arguments for shareholder primacy. However, recent literature (such as Rojas 2014) builds upon Jensen's work arguing in favor of a dynamic model of the corporation and theory of corporate governance.