Tackney v. United States Naval Academy Alumni Association, Inc. (Ct. of Appeals)

Filed May 14, 2009.
Opinion by Judge Clayton Greene, Jr.

Held: Ordinarily, Maryland courts will not interfere in the internal affairs of a voluntary membership organization unless there is evidence of fraud, irregularity, or arbitrary action.

Affirming the Circuit Court's dismissal of a challenge to an election of trustees in a voluntary membership organization for failure to state a claim. Pursuant to the standard elucidated in NAACP v. Golding, 342 Md. 663, 678, 679 A.2d 554, 561 (1996), the Court of Appeals found the board's actions not sufficiently arbitrary to warrant intervention in the organization's internal affairs.

The full opinion is available in PDF.