The law has certainly evolved over time into the business judgment rule...but that only muddys the waters more than the maximization rule from dodge v ford. We see new types of cases from shareholders against boards/officers all the time, including, but not limited to political donations; increasing corporate expensive for more environmentally friendly supply chains; and similar issues of selling product for loss.

These shareholders would likely win all the time under dodge v ford, but now they win some and lose some under business judgment rule based on the taste of the jurisdiction/jury. The reality is case law provides only some clues and the waters are muddy until a given set of facts is tested, and I'm not saying I like the shareholder maximization rule over business judgment but I do prefer bright line rules over balancing acts.