Steven Scheire v. International Show Car Association (Isca)

Plaintiff Scheire appeals from summary judgment in favor of defendant International Show Car Association (ISCA) on a breach of contract claim and a fraud claim. We affirm.

Jurisdiction in this case is based on diversity of citizenship. There is no conflict of law between California, the forum state, and Michigan, the ISCA’s state of incorporation, regarding the contractual nature of membership in a voluntary association. We therefore need not reach the issue of which law applies.

The principle of judicial noninterference in internal disputes of voluntary associations should not be applied mechanically. See Koszela v. National Association of Stock Car Auto Racing, Inc., 646 F.2d 749, 754 (2d Cir.1981). Thus courts have reviewed an association’s decisions where, for instance, the organization unreasonably construed a plain and unambiguous provision, of its constitution. California Dental Association v. American Dental Association, 23 Cal.3d 346, 354 , 590 P.2d 401, 406 , 152 Cal.Rptr. 546, 551 (1979) (citing Mandracio v. Bartenders Union, Local 41, 41 Cal.2d 81 , 256 P.2d 927 (1953)). In determining whether judicial review is appropriate, we first ask whether the association has…