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It requires that the particular stockholders be actually culpable and involved in the fraud - fraud done by non-owning management would not allow to capture funds of non-managing investors.

piercing the veil usually applies to manager-owners, like S-corps. If I invest in a corporation and the managers do something horrible, the managers could potentially be reached through the veil, but not the stockholders -- their only involvement was handing over money, so they had no wrongdoing.

Now, investors who are also decision-makers on the Board or maangement, that's another story.

What I'm saying is the culpable stockholders (Holmes being the primary one) have few assets.