Earlier this week, the Seventh Circuit reminded us that Indiana courts do not interfere with a voluntary association’s internal affairs—like membership decisions—absent some showing of “fraud, other illegality, or abuse of civil or property rights.” It cited 𝘐𝘯𝘥𝘪𝘢𝘯𝘢 𝘏𝘪𝘨𝘩 𝘚𝘤𝘩𝘰𝘰𝘭 𝘈𝘵𝘩𝘭𝘦𝘵𝘪𝘤 𝘈𝘴𝘴𝘰𝘤𝘪𝘢𝘵𝘪𝘰𝘯 𝘷. 𝘙𝘦𝘺𝘦𝘴 and affirmed the lower court’s dismissal in an unpublished order without oral argument.
The appeal involved a pro se plaintiff who sued his fraternity because it terminated his lifetime membership for allegedly arbitrary and personal reasons. As the court explained, “Misapplying the organization’s rules, however, is not in itself illegal or fraudulent.” Because it was “an internal matter,” it is “not subject to judicial intervention.”
Nothing new or exciting, but it reminds us of the broad leeway Indiana membership nonprofits—including religious organizations—have in policing their own procedures.
Read the order here.