There are dissenting papers [2] mostly revolving upon Dodge v. Ford Motor Company, but there are many intractable problems when you assert such primacy. Over what duration? As compared to which company? Accounting for intangibles? Valuation of non-monetary factors? Accounting for market gyrations? Primacy by what percentage? That dissenting paper glosses over much of the nuance of Stout's thesis [3], as well as case law ever since that point to the problematic practicalities of courts deciding how companies should carry out the distribution of the benefits of organizing stakeholders together.
So many people who should know better keep repeating this canard. Shareholders can certainly mount a challenge through corporate governance channels for example, but they fare poorly when mounting a challenge through the courts.
[1] https://corpgov.law.harvard.edu/2012/06/26/the-shareholder-v...
[2] https://clsbluesky.law.columbia.edu/2022/04/26/why-we-should...
[3] https://scholarship.law.cornell.edu/cgi/viewcontent.cgi?arti...